Subject: File No. 4-606
From: Paul A Stern
Affiliation: 34 year insurance veteran

August 24, 2010

The Fiduciary standard proposal is very misguided. Of the tens of thousands of registered representatives, how many do Madoff and Sanford represent? The additional oversight and compliance for what I do (not a stock broker or a RIA) working with clients with products like variable annuities and life insurance and mutual funds is both overkill and a tragic waste of time and money.

Martha Stewart used inside information and wasn't even prosecuted for her offense, so why try and bring a sledge hammer to the table when dealing with Registered Representatives of insurance companies? Those with a full series 7 license should be supervised and held accountable, but the act is way too restrictive for what I do.