Subject: File No. 4-606
From: Barry N Berlin, CFA
Affiliation: Managing Director, Atlantic Trust Company

March 27, 2013

In our industry, personal/organizational integrity should not be a differentiator...yet that is the case. My employer abides by a strong fiduciary standard as a legal necessity (we are a trust company), but we have found the resulting culture to be highly differentiating versus competitors who adhere to a lesser standard. While I shouldn't argue for raising the bar for our competitors, I think most would have a very difficult time adapting to a changed environment, perhaps distancing our firm even further. To that end, I would end arbitration as the format for handling disputes with "advisors" in the broker/dealer system, and allow mishandled clients access to the courts. This would change behavior among the worst offenders.