Subject: File No.
From: Diana Johnston, CLU, ChFC

November 5, 2010

I don't understand your thought process regarding allowing b/ds to compete with each other by setting their own commission structure based on the services they provide. Each individual representative of a broker/dealer may have varying degrees of service to their clients, some choosing to provide value-added options that others may not choose to offer. By having the commission level set by the broker/dealer you are promoting a potential atmosphere of cut-throat bidding wars where reps will scurry from b/d to b/d in order to gain the greatest compensation level, regardless of the level of service they provide to their clients.

By keeping the commissions structure at the product sponsor level, we are all on the same playing field and reps are going to be better able to make decisions on the level of service they provide to their customers for reasons other than compensation...meaning because it's in their client's best interest, instead of their wallet's best interest.

I encourage you to keep the commission structure at the sponsor level. It will most certainly be in the public's best interest to have it remain so.