Subject: File No. 4-606
From: Mark A Reed
Affiliation: NAIFA

August 24, 2010

I believe this proposal should be REJECTED.

To Retroactively set a Standard that was not in place at a time is in affect changing the rules after the game has ended. We operated under one assumption and then are Judged so to speak by another later. You should have or could have or might have. That is clearly an attack on the industry and some form of Trial Lawyers manner to find a way to capitalize and use the Goverment as its own rule maker.

This is slanted not neutral or to help the consumer. The words may be said but the methods are enforcement of control of areas that people want to have. This only builds up Goverment not decrease or improve it.

The other reason is that oversight is already in place. Duplicity is wrong.

You are shooting everyone in a room in an effort to hit a few. Not everyone should be subjected to this and also the funds spent when proper use of the resources and agencies you have can already achieve any goal.