Subject: File No. 4-606
From: Roger S McCullough, CLU
Affiliation: NAIFA

August 18, 2010

Ms. Murphy: Thank you for the opportunity to render comment as you consider the development of rules governing brokers, dealers and investment advisors when providing investment advice to my clientele. I am primarily a life insurance agent with a focus on retirement planning. Many of the products which I market are under the regulation of FINRA, as well as State Insurance regulators and in some cases your organization. It is my belief that at the retail level this area is currently subject to extensive regulation and ongoing monitoring. Having worked with my clients, many for over 25 years, on a relationship basis I now find much of my time and attention is drawn away from giving service and care to my clients and must be focused on regulatory concerns. If there are areas which could benefit from the application of additional standards and/or regulation I am unaware of where that may exist. I believe you will damage the public and reduce the services available to them if your efforts are not highly focused with consideration for the unintended consequences which may occur as a result of your action. I urge you to not yield to political winds which blow without concern for the public it is designed to serve. Thank you for your consideration.