Subject: File No. 4-606
From: Robert L Rifkin
Affiliation: NAIFA, MassMutual

August 2, 2010

I am a long time Life Insurance Agent and Registered Representative. While I understand the need for compliance, adding another layer which is standard for everyone will be more of a burden as opposed to a benefit for consumers.

Currently I am examined in essence every day as my emails and written correspondence is monitored. In addition, I am subject to full day annual compliance meetings, personal interviews with my compliance officer along with file inspection. All marketing material must be reviewed and approved generating a lot of paperwork and taking a lot of time. This is very costly not only to me personally, but to the industry. Don't these costs just get passed through to the consumer?

Regulation for the sake of making more rules is inefficient. It does not protect against the unscrupulous individuals or organizations.