Subject: File No. 4-606
From: David Sewell
Affiliation: NAIFA

August 24, 2010

I am concerned that as a registered rep I am going to be regulated to death. We already have suitability forms to assess what kind of investment a client should have. We are audited every 2 yrs by our company to determine whether we have followed their guidlines. Currently the paperwork and record keeping has put a damper on agents desire to work with smaller investors, and any additional regulations will probably result in small investors having no one help them because the mountain of paperwork isn't worth the time it takes to fill out. I already see it happening on the life insurance side of our business. More and more companies are raising the minimum death benefit to cover the costs of implementing a policy and meeting suitability guidlines, and agents no longer look to write small policies. If you proceed with additional regulations on investments those same companies will raise the minimum initial investment so that they can cover the additional costs associated with the increased regulation and liabilities. Due to the current regulations companies have already raise some initial investment minimums. These higher initial investment requirements leave the smaller investor on the sidelines with no one to help them invest wisely. The result is they will chase returns, always behind and never realizing their expected returns. Additional regulation will not help small investors it will eliminate them from the process.