Subject: File No. 4-606
From: Darby J. Minnick
Affiliation: Clu,Chfc

August 19, 2010

I have been in the financial services business for over 30 years, hold many licenses that require compliance review, carry a lot of errors and omissions coverage and spend a lot of time keeping current and being reviewed by all the regulatory bodies that I'm involved with. When I started I was a life insurance agent with Northwestern Mutual, all that was required was an insurance license. As time went by I was required to keep adding securities licenses to sell products I may or may not ever sell. What I have learned over the years is that honest people try to do what is right, dishonest people don't always do what is right and people who don't understand the difference are not always dumb, usually just uneducated. With the educational and compliance requirements that we currently have you become educated. The problems I have seen are that educated, dishonest people are almost impossible to catch, example Mr. Madoff, the vast majority of people with the current rules are probably being held to a high enough standard today.