Subject: File No. 4-606
From: Keith D Hennessey
Affiliation: CLU, LUTCF, National Association of Financial and Insurance Advisors

July 30, 2010

Compliance costs-both in terms of finances and time-are high, and those costs are eventually felt by clients. Adding another layer of regulation means another layer of compliance, and even more cost to clients.

Our broker-dealer already does higher than standard care on compliance issues.

Over-regulation is not what is needed