Subject: File No. 4-606
From: Chad Franks
Affiliation: New York Life/NYLIFE Securities

July 30, 2010

I disagree with the SEC's attempts at governing investment advisors based on a legal/fiduciary capacity vs. ongoing suitability standards which look forward to effectively deisgn policy and procedural governnance. The ethical commitment and oath Advisors take in order to become an Advisor should ultimately the governing authority, but I understand that legality is still required. We must not allow legal governance to override morality. Legal governance is designed to support morality, not dictate it.