Subject: File No. 4-606
From: Waylon F Peterson
Affiliation: Senior Vice President, TCU Investment, Trust and IRA Services

July 30, 2010

I am the Senior Vice President with responsibility for Investment, IRA and Trust Services at TCU. Our team serves almost 20,000 households with assets over $450 million in investment, IRA, trust and health savings accounts.

With my fifteen years of experience in the financial services industry and as a current member of the CUNA Brokerage Services new products committee that approves products for hundreds of credit unions across the country, and as a former legislative aide who handled banking, finance, trade and insurance issues on Capitol Hill, I believe a level playing field for all "financial professionals" is in our countrys best interest.

All of TCUs 14 financial advisors are Indiana life-and health-licensed and securities-licensed and seven of them, including me, have our CFP designations. In the interest of all investors, those who consider themselves financial professionals—not just those who hold securities licenses—should be held to a standard that is clear and uniform. A life insurance agent, who is not securities licensed, should continue to promote non-securities products, but they should be held to the common standard as well. As long as the standard is clear, uniform and enforceable, the suitable or fiduciary definition is less important.

Also, I know the NAIC has taken steps to standardize the annuity suitablity rules, but many of the annuity products that are approved by the 50 different states may not be in the best interest of policyholders. I believe a common standard for all states would be of benefit to all Americans. States should not approve any annuity products that have a surrender charge time period over ten years and/or a surrender charge penalty over ten percent, and/or a commission over 10 percent over the length of the surrender charge period.


Waylon Peterson