Subject: File No. 4-606
From: Robert H Perry, CLU,ChFC
Affiliation: Member NAIFA, MDRT, New York Life Financial Professional

August 6, 2010

I wonder if any of you have been in the shoes of a Financial Professional working with actual people in the middle market of the USA? New York Life's standards of suitability go far to oversee and protect these fine people and are far superior to the retospective look your fiduciary standard might demand. After 34 years with New York Life here in SLC I've seen the major changes to our industry proposed at various times by government entities. I stand by the statement that if more companies followed NYL's suitability requirements, there would be no need for the increased regulation of which you speak.
Please consider urging other companies and their Broker-Dealer affiliates to enforce the current suitability standards required of NYL registered reps.
I wish you well in your duties and urge you to hold to the current suitablity standard vis vis the proposed fiduciary standard.

Robert H Perry CLU, ChFC