Subject: File No. 4-606
From: Bill Staton
Affiliation: Wharton MBA, CFA

March 27, 2013

I think the same high-fiduciary standard should apply to everyone in every field who gives financial advice or sells financial products like annuities and variable life insurance.

It is appalling to hear from some clients how they have been seduced by the word "guaranteed" which is and should be forbidden by an RIA firm like mine to use. It should also be banned in every corner of the financial arena in every respect.

When the Committee for Fiduciary Standard began last year, Staton Financial Advisors LLC was the fourth firm to join the cause. We maintain the strictest ethical and legal behavior. Why shouldn't all our counterparts?

Thank you,

Bill Staton, MBA, CFA