Subject: File No. 4-606
From: Patricia Mann, CLU
Affiliation: Managing Partner New York Life Ins Co./NYLIFE Securities

July 30, 2010

What confounds me, after 30 years of serving our clients, is there has been zero progress in the ability to catch or identify crooks in our industry. (Ex. Madoff). These individuals and firms are very smart and appeal to people's greed. The public would be served quite well if only they heeded the old adage: If it sounds too good to be true......
What is truely sad for our citizens is, despite all the layers of scrutiny and compliance that has been dealt to our industry, people are in worse financial shape then ever before.
People are not at all prepared to retire, deal with family members who will require elder care or provide our children with a debt free college education.
If additional, complicated legislation is piled on to our entire industry because of the crook's behavior, you are making it even more expensive and confusing for our citizens and consumers.

PLUS- I don't think any amount of expensive compliance measures will effectively catch crooks in a timely fashion. And, there will always be consumers fueled by greed, looking for a bigger, better deal who are the perfect prey. P.T. Barnum- "a fool and his money are soon seperated" or did he say: "a sucker is born every minute"

Perhaps a better approach to help our consumers would be to measure or rate or publish the promises kept by companies. Did the product or service do what it was intended to do? Are our citizens better prepared to retire, etc...? The desired outcome of all the compliance legislation is to help our clients achieve their financial goals- isn't it? And that can in no way be measured in the short run.

Approximately 15% of my time and having a compliance officer on staff ultimately costs the consumer dearly. Adding more to this will cost the consumer even more.

Thank you. I still believe our legislature is trying to work for the best interest of it's citizens- but, is often helpless to stop greed and ignorance.