Subject: File No. 4-606
From: David S. Cochran
Affiliation: life insurance agent

August 24, 2010

Imposing a fiduciary standard to fixed life insurance agents creates two problems that could and I believe will destory the industry. One, it looks back on activities that the SEC "might" view as not in the best interest of the client. Our career is based on actively marketing to prospects for life insurance policies that have company guarantees. The more we market the more exposure we have of a SEC fine. Second, a fiduciary standard will make us disclose all commissions that are paid to us by the insurance company. If that is the case, I believe the SEC will at some point say that it is in the best interest of the client to not pay commissions for the sale of a life insurance product. This is not a profitable business as a "fee based" business and the industry will move to have banks as the only seller. That result would not be in the best interest of any client or of my business.