Comment on FR Doc # 2010-29596

I understand that commissions paid to brokers are to be included in the loss ratios to determine the 80% threshold. I believe that is a grievous mistake. I have been employed in the health insurance industry for 28 years both on the insurance company side and the brokerage/agency side of the business. I have witness first hand as an insurance co. employee the outstanding services provided to insureds by agents, that go well above the commission payments they receive. Now as a broker/agent I deal everyday with service issues that insurance companies could not possibly handle if brokers were to dissapear. If commissions are included in the bill then ins.cos will lower the rate they pay which is already a fraction of what it was 10 years ago. A valuable and inexpensive source of help will be lost to the gen public.