Subject: File No. 4-606
From: David L Rees
Affiliation: Agent with Allstate Insurance

July 30, 2010

Please consider this:
Compliance costs are high, -both in terms of finances and time-and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients. This can be a major concern for the clients as well as the agencies trying to do what is best for the client interests.

I currently hold a PC license, Life and Health, Series 6 and Series 63 in order to provide the best for the clients that I work with. Each year I must complete about 6 classes and compliance processes along with multiple Continuing Education options in order to hold this license.

We are examined at least once or twice each year to be sure that our compliance meets the expectations of the SEC. I am happy to do what is asked but quite frankly we spend numerous hours and countless amounts of time keeping these records straight and organized as requested. Sometimes it is difficult to consider hiring additional staff to handle this because of the additional costs to us and the difficulties in generating the income necessary to pay for the added help. So I do my best to make sure it is in order myself. Many times, however the amount of compliance work that is done keeps me from giving the clients the time and devoted service that they deserve in a reasonable time frame.

A fee based approach could be the only way to give the client the appropriate assistance and that will deter many customers from even asking for help as they may not be able to afford that cost. The added compliance responses may require the liabilities for EO coveage to drive the premiums upward. It may even be questionable whether it is feasible to stay in this business due to the expectations.

Please carefully consider the impact over the long haul, to the client.