Subject: File No. 4-606
From: David A Beaty, CLU,ChFC
Affiliation: Investmetn Advisor Representative

August 3, 2010

For Investment Advisors, a objective unbiased analysis of the situation and recommendation of product by class (ie, fixed, variable, life, annuity, mutual fund etc) is essential. However under insurance law an agent is required to represent both the client and the insurnace company interests. This responsibility is and has been the law for a long time. Agents are required to disclose the relationship with the carrier(s) as part of their relationship with the client as part of the disclosures. As such the fidiciary standard of product/vendor neutrality is untenable under insurance regulation and is not expected from the consuming public. Consumers know that you will get a Ford from a Ford Dealership. They also realize that you get a New York Life life insurnace policy from a New York Life agent. A high level of Fidiciary Standard is important as part of the planning process, implementation especially with 'Captive' agents/brokers is not practical or reasonable.