Subject: File No. 4-606
From: Richard A Koob, CLU ChFC, AEP
Affiliation: NAIFA

August 23, 2010

I am currently acting in the best interest of my clients. This act does not define rules for compliance with a legal best interest. Please define "BEST"??? This is a vague legal liability standard that does nothing more than encouage a lookback many years after the fact and after the economy has changed in an unforseen direction.