Subject: File No. 4-606
From: Michael Scott

January 7, 2012

My name is MIchael Scott and I agree that Brokers need to be held to a higher fiduciary standard. What I find disturbing though is that advisors as well as brokers do act in their own best interest and most of the time do not make cost comparisons between different products and are not required to under current standards. Should they be doing so? Yes. But do they? No. Those affected most are the Middle and Low Income individuals, epecially those nearing retirement age.

The Variable Annuity market has its place, but 100% of an individuals assets should not be tied up in these products and yes, the cost of these products outweigh the benefits. Also, these Variable products with their riders are sold with verbal promises of "All it takes is one good year and you will never lose a dime and will be so far ahead." The reality though is that this is only a verbal sales pitch and the markets can be unforgiving. I know I could give specific instances and companies that advisors are taught to sell this way. But that is not the intent of this letter. There needs to be strictor laws for both Brokers and Advisors. How that is to be done is the toughest part of it all. Money can and does change things and people.