Subject: File No. 4-606
From: Joachim Klement, CFA
Affiliation: CIO

April 4, 2013

Even though I am not a practitioner in the United States and thus will not be directly affected by the regulations of the SEC, I would like to encourage the SEC to adopt a uniform obligation to adhere to the standards of fiduciary duty for all financial advisors, brokers and security dealers.

Putting clients interests first should go without saying for every practitioner in the financial industry. However, in the absence of such regulatory requirements investors have little power to protect themselves from malfeasance.

Also, the standards in the United States still are a model for other countries around the world. striving to improve investment standards around the world the SEC should adopt the standard of fiduciary duty and encourage other countries to do the same.