Subject: File No. 4-606
From: Brian E Worrell
Affiliation: agent with Prudential Financial

August 2, 2010

Imposing a legal fiduciary standard on broker-dealers and their registered representatives, would be a mistake. Imposing new standards , without justification or analysis , on life insurance agents who sell variable life products and are rigorously regulated both by state insurance departments and would be particularly harmful. The proposed standard would disrupt the current distribution system relied upon by 75 million American families, increasing costs, and decreasing options of products and financial service providers. The current suitability standard governing broker-dealers and registered reps is a robust and heavily enforced standard.In my office there is a fulltime compliance officer and every piece of business that I submit is additionally screened by the home office compliance department.