Subject: File No. 4-606
From: Maneesh Shanbhag
Affiliation: Head of Investments, Greenline Partners, LLC

March 30, 2013

There is so much wrong with our industry that it is hard to know where to start but I will try to stay to the point of this request.

There is no reason why brokers should be held to a different, lower standard than investment advisors. I believe it's a disservice to customers. Especially when it tends to be smaller, less sophisticated investors go to brokers and larger investors can meet the minimums of investment advisors who are held to a fiduciary standard.

Investing is like health care, very complex to the uninitiated yet has life long consequences for those who are not well served (which today, appears to be the majority). Therefore every advisor and broker should be held to the same standard and required to disclose to their clients, in big bold print, up front in a presentation for example on 3 things: 1) conflicts of interest 2) total costs and fees compared to alternatives and 3) odds of success.

1. On conflicts of interest, this involves disclosing commissions paid to the broker for recommending a product and showing the client comparing the recommended product to the universe of comparable products for which the broker would not receive a commission (i.e. compare along the lines of historical performance and fees). This involves disclosing clearly how much of a mutual fund's track record is from an incubation periods, and how much is real. This involves an advisor or broker disclosing sales load charges or other fees being paid, the impact on return over 1- 3- and 5-yrs and showing the client comparable products that may not have such up front or high costs. This involves advisors and brokers at large, multi-division companies like banks, disclosing how they are persuaded to sell products created in house.

2. Fees and costs are still not disclosed as boldly as they need to be. Fees and costs drive investment returns over the long term more than anything except, including asset allocation. Customers need to understand the impact of advisor fees, investment fund fees, estimated transaction costs, taxes and how all of these eat into returns over time. In the past, when returns were high, high fees and costs were masked by the returns. If it is true that we are in a lower returning world, people will notice the fees and costs only when it's too late, after they have been lost to high fee mutual funds, brokers, and investment advisors.

Slides attached that illustrate the above.

3. Finally, the odds of success need to be illustrated to people in a way they can understand as well. Whether investing passively or actively, everything has odds of success. The odds of active trading are far worst that most people understand them to be. Every single investment client needs to be shown this. It is a huge loss to society if we don't. The $100's of billions of dollars that investors hand over to investment professionals every year is a drain on their savings and therefore a burden on society as few will be able to live off their retirement savings in this and the next generation. If people understand the odds of success when trying to trade or actively manage their portfolios, they may make wiser decisions (similar to trying to reduce their fees above).

Slide 4 in attached illustrate the odds of success of selecting an advisor who can beat the market. Very low. It gets clients to think about and acknowledge the risks they are taking.

Slide 5 in the attached illustrates the upside vs. downside return profile of trying to beat the market (vs. just passive investing). This is only meant as an illustrative example but gets the point across. This can be used to show that when a broker recommends a trade, that after taxes and costs, the trade may have a return profile that is not favorable.