Subject: File No. 4-606
From: Anthony G Jabaley, Jr
Affiliation: CEO, Andy Jabaley State Farm Agency

August 26, 2010

As a Registered Representative for State Farm VP Management Corp, I oppose the Fiduciary Standard regulation due to the additional cost of time and money that a Fiduciary standard would have on my business. Presently, SFVPMC has a full compliance unit that reviews each and every file to make sure it complies with our Company's stringent guidelines. This is an active roll before an account is processed, not an after the fact passive action after an account has been opened.

Our goal is to always act in the best interests of our clients, and we regard ethical behavior and integrity as some of the most important aspects of how we deal with our clients on a daily basis.

I believe more attention should be placed on looking at suitability issues within companies rather than subjecting Registered Representatives to potentially frivilous legal action. Investing will always have risks involved, and these risks must be communicated correctly to our clients as a whole. Our industry should not be subjected to Fiduciary Standard legal action as a means of improving the safety of client funds or purchases.

As it is now, over half of the time to complete a transaction for a client is spent on Suitability information to make sure we put ample attention to the suitability issues. Please consider all these factors when you evaluate this new legislation.

Andy Jabaley, CPCU, ARM
Register Representative