Subject: File No. 4-606
From: Robert Sanders, III
Affiliation: NAIFA

August 24, 2010

There are already too many securities regulations in place. The time and effort that it takes in order to maintain compliance with these translate into increased costs for the consumer. The simple fact is that regulations equal compliance and compliance equals cost/time and that ends up being paid by the consumer which cannot stand any more. In additions to costs the additional time it would take to maintain compliance would cut down on the time available to spend with clients, which is where agents can help. Removing efficiency from a system that is already bogged down in paperwork, compliance, etc. is eventually going to kill the motivation to participate. Maybe that is the motive here.

In addition to the increase in time and compliance costs there is the increased risk of liability. The cost of this will end up in fees to the consumer or again drive agents away from participation.