Subject: File No. 4-606
From: Lester M Halstead, Jr.
Affiliation: MFP, CFP, CSNP

July 30, 2010

Contrary to NAIFA's position, I support the imposition of higher standards for all licensed individuals (securities and insurance) in regards to their responsibility to look out for their client's best interest.

There should be a level playing field for all those who are selling equity related products (variable, equity-indexed, etc.) and everyone should have to answer to the same code of conduct.

Many insurance agents sell equity-indexed products and have no concept of the securities markets upon which those indexes are based. I feel that securities registration should be mandatory for those who sell any equity related product and that they should have the same disclosure of conflict of interest.

I will really raise the ire of my colleagues when I state that all compensation should be fully disclosed to the client so that the client understands fully the motivations to make the sale. I believe that mandatory disclosure would create a more competitive landscape for the consumer and lower the cost of insurance substantially.


Lester M. Halstead, Jr.