Subject: File No. 4-606
From: Robert A Swanson, Jr
Affiliation: Sales Manager, Ameritas Financial Services

August 12, 2010

New fiduciary standards are not necessary, will not ensure better service or more transparency, and will lead to higher costs for the consumer. Additional regulations will make the vast majority of honest advisors jump through unnecessary hoops and expense, while any dishonest/unethical representatives will continue to find new ways to practice. These new regulations are unlikely to accomplish the desired good, but likely to interfere with the sound and ethical practice of most representatives. Stiffer penalties for transgressions may be more appropriate. Clients need and want our services don't drive us away through political posturing.