Subject: File No. 4-606
From: W. Craig Gibson
Affiliation: Agent : New York Life Insurance Company

August 2, 2010

I am a regestered rep with a series 6,63,22 lic. I am currently audited a min of once per quarter by somebody in the compliance field. The amount of time spent in preperation for this is approx 4 to 8 hours per audit. A number of the preperations are for the convience of the auditers and do not actually help in protecting clients.
Moving to a fiduciary duty model would force me to go to a fee only service that many of my clients could not afford or would be unwilling to pay. I do not see how this would in any way protect clients but could make doing business much more combersom and expensive. More regulation is not needed just better use of the current rules of "best interest" to protect the client. I am agenst a fiduciary model of regulation and feel another layer of regulation and bureacratic oversite is just an added expense to the client.