Subject: File No. 4-606
From: James P Grogan
Affiliation: Managing Direct or the Northwestern Mutual Life

August 24, 2010

I have been a rep or MD with the Northwestern Mutual for the past 23 years and manage 25 reps in my office. To institute this extra layer of fiduciary responsiblility on FR's would casue a real problem for our clients. Because of the increase in manpower for compliance for both the office and the rep, more fee based accounts would be choses. This may not be in the best interest of the client, who is our number 1 concern. Please do not approve of this increase in obligations of advisors, dealers and investment advisor's.
Thanks Jim