Subject: File No. 4-606
From: Joseph W. Cirencione
Affiliation: LUTCF, CLTC

August 13, 2010

Please note that the suitability standard governing broker-dealers and registered representatives is a very robust and heavily enforced standard. Compliance costs both in terms of finances and time are high and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more costs.

I currently hold life and health licenses in 5 states and I work hard to maintain the education requirements in all the states. I continually take advanced courses to stay abreast of current laws and to provide my clients with the most up date information possible concerning their insurance and investment needs. I've just completed and passed a course from the American College(ETHICS FOR THE FINANCIAL SERVICES PROFESSIONAL) in order to further educate myself on the best ways to serve and protect my clients as I advise them.

I truly don't feel that another layer of bureacratic red tape serves the public or the industry.

Moving to a fee only model does not protect anyone. The advisor needs to hold his clients interests higher than his own. Many clients today can not afford to pay fees and many will not be willing to.

Please consider voting against the Dodd-Frank Act as it does nothing to enhance the public protection. This will only add more red tape to a overly red taped industry while not adding any real protection for consumers.

Thank you for your attention to this matter.

Joe Cirencione, LUTCF, CLTC