Subject: File No. 4-606
From: John A Vita, Jr.
Affiliation: NAIFA

August 5, 2010

I think that this is overkill to an already much-policed sector of the investment world, especially given the hoops that we have to jump through in New York State as far as compliance is concerned. The bottom line is that any further compliance regulation will hit the already burdened consumers. They will pay the price for the additional costs incurred by these regulations in the form of lower guaranteed rates, higher expenses, etc. Americans were hit hard in 2008 and the market is still lagging in recovery despite the fact that interest rates remain low. The domino effect will see consumer confidence plummet anew because they are going to be hit with more charges as a result of these compliance regulations.