Subject: File No. 4-606
From: James H Blassingham, CLU
Affiliation: Financial Advisor - AXA Advisors

August 6, 2010

I have been in the insurance business since 1976 and offering securities since 1988. I am currently appointed with AXA Advisors, a company that take their compliance with regulations very seriously. I have the following licenses 6, 63, 65, 22, 7 and I am licensed for life and health and variable annuities in several states. I provide both fee and non fee commission based services and take my responsibility of offering ethical financial advice to my clients very seriously.
We have numerous compliance regulations in place to govern the services and recommendations we provide to our clients and adding a fidicuary liability layer will ony serve to diminish the services we currently provide. The only people that are likely to benefit from implementing this change will be lawyers. There are already enough regulations governing the behavior of Financial Advisors and I believe that the majority of Advisors hold themselves to very high ethical standards already. It seems very punitive to punish the majority with additional regulations that will have a very negative impact on our careers and the services we offer because of the inappropiate actions of a few Advisors.
I am examnined twice a year by our firm's compliance officer and spend hours each day making sure that we are keeping accurate files, notes, copies of all the applications and forms required to complete even the most simple of transactions.
I am not sure how I would deal with this additional regulation but it could force me to provide only fee based advice and many of our clients would not be willing or able to pay those fees. Only the very wealthy will be able to benefit from our service thereby leaving a huge majority of our population without credible financial services and possibly increase the potential of having unscrupulous individuals take advantage of them.
I already pay over $2,500/ year form my E O insurance and there is no telling how much that might go up and we are all paying for the service of our firms administrative and compliance services in addition to all our other overhead.
Please consider maintaining the curent format for Advisor regulation.


James Blassingham, CLU