Subject: File No. 4-606
From: John Lefferts, CFP,CLU,ChFC
Affiliation: N/A

August 17, 2010

I have a background as an state regulated insurance agent, FINRA regulated Broker/Dealer and SEC regulated Investment Advisor, each with their own set of rules, procedures, requirements and registrations. And this for essentially performing the same service to clients by giving quality personalized investment advice. It's confusing to the advisor, broker and agent as much as it is to the investing public as to why this duplication of oversight is required. So long as proprietary and commission based products are allowed as appropriate under a harmonized standard of fiduciary care, I support new regulations that drop the separation of brokers and advisors by holding all to an equal standard. Further, I urge you to find a way to separate life and annuity licensed insurance agents from state oversight as their activities more closely align with brokers and advisors. States should keep oversight of all other forms of insurance, but life and annuity forms of insurance advisors fall into the category of giving "personalized investment advice" and should be regulated accordingly.