Subject: File No. 4-606
From: Martin K. Green, Jr, CLU, ChFC
Affiliation: NYLIAC

August 6, 2010

I am opposed to chnaging the present suitability standaard for Broker Dealers to a fiduciary standard. We are regulated enough. The present standard is certainly robust and heavily enforced as is. In order to comply with the existing standard I would estimate 25 manhours per year per producer is already being spent in cmpliance audits, training, documentation, and other areas which are necessary to remain up to date with regulatory changes and industry best practices in the current changing regulatory environment.
I do not believe a change to the fiduciary model will reslt in better client service or advice. I blieve it will only add to the burdens imposed in the present regulatory environment, and will only bring costs up for the client and rduce the number of individuals serving this market.