Subject: File No. 4-606
From: Ryan Schulte

August 24, 2010

As a registered investment advisor representative, I believe the needs of my clients should always come first. As such, I always have and always will do the best I can to do what is in their best interest. This is not easy however. Determining what is in someones best interest takes a lot of information, and time. And some clients simply aren't willing to put the time in to provide that information. In order to determine what is in someone's best interest, I need to review all of their financial information as one unknown document could change the direction of everything. So imagine that I would need to review all of their retirement accounts,investment acocunts, checking accounts, CD's, annuities, auto and homeowners policies, tax returns, balance sheet paytstubs, life insurance policies, employer benefits, disability insurance policies, trust documents, ownership deeds, power of attorney documents, and so on and so on- simply to sell them a life insurance policy. Not only is this unnecessary and burdensome for the agent involved or Registered representaive involved, it is also an onerous task to put the client thru. And it's just not necessary. Determining what is in one's best interest is not easy. And simply put, RR's and agents will not do it for middle income people. There simply won't be enough profit involved to work with middle to lower income people. And what this will lead to is less protection for an already underinsured population that by and large rely on their Human resource director to protect their family and provide for their retirement- and it isn't happening. American's will be retiring poorer than ever, and they don't need more roadblocks in their way. Applying a fiduciary standard to insurance agents and RR's will not help the "average american".