Subject: File No. 4-606
From: Lanny Kuehl
Affiliation: New York Life

August 24, 2010

In my opinion there is no need for additional rules. The ones we have need to be inforced. We have too many forms etc. to complete now, thus driving up the cost of business. Our clientele complain now about the cost attributed to the distribution and servicing of the securities markets. We need not add to this burden. If any additional scrutiny is needed it is with small firms that have one or two principals who are the ones who think they can reinvent the wheel.