Subject: File No. 4-606
From: David L Rees
Affiliation: NAIFA - Allstate Insurance Company

August 24, 2010

Please reconsider the intensity of the fiduciary standards that are being considered. Compliance today is extensive and I believe that they are adequate. Standards should be related the the BEST INTEREST of the client and from what I can see, these proposed standards do not take into account what is best for the Client. The fiduciary standard in essence adds a vague legal liability standard that looks back (sometimes after many years) and is enforced after the fact. How do the enforcers know in retrospect what was best for the client? I understand the need for close watch of the industry but I believe that there needs to be more clarity in the language submitted.

Please consider the ramifications to the client as well as to the responsible producers who work hard to do what is right.

Thanks for your consideration.