Subject: File No. 4-606
From: Sean P Swanson
Affiliation: Partner, New York Life

August 12, 2010

#9650 Suitability standards currently governing broker-dealers and registered representatives are already stringent and heavily enforced. Current regulations already provide strong and appropriate consumer safeguards.
#9650 Requiring compliance with 'fiduciary standards' will drive many advisers out of the market and eliminate a valuable advisory resource to consumers, especially in middle- and lower-income markets.
#9650 Additional risk of lawsuits involving registered representatives will increase costs to consumers.
#9650 Driving every registered representative to fee-only compensation will not necessarily result in better, unbiased advice for the consumer.