Subject: File No. 4-606
From: Earl Adler, CLU
Affiliation: Pres. EACO, Inc.

August 11, 2010

Your oversight lumps all security licensed professionals together ee: security salesmen,brokerage firms, broker dealers and life insurance salesmen that sell only variable life insurance policies.

Those selling securities to the public need much greater and different oversight than a BD or life salesman selling only a registered insurance product, that you improperly call a "security". Few at the SEC nor the NASD truly understand the difference and the nature of the products.