Subject: File No. 4-606
From: Max A Widmer, CFA

March 27, 2013

To whom it may concern,
I have been active in the financial services profession in the U.S. and Europe for over twenty years and am CFA Charterholder since 2000.
I feel that the last couple of crises could somehow have been mitigated was there a more stringent and (globally) uniform standard for financial professionals. In my experience I have encountered numerous times were I had to rectify other advisors comments and suggestions for a clear lack of knowledge worse, the party involved would not even acknowledge that. Furthermore, the industry itself should be more consistent and uniform in the way these standards are to be implemented and monitored.
I fully concur with the CFA Institutes that supports
1. adopting a single, definable, and enforceable standard of care
2. establishing a consistent treatment of all individuals and firms that engage in similar activities
3. applying such a standard when broker-dealers provide personalized investment advice to retail investors
4. a fiduciary level standard that requires the duties of prudence, loyalty, and care for those who provide personalized investment advice
Best wishes