The following Letter Type I, or variations thereof, was submitted by individuals or entities.

Letter Type I:

As an investment adviser with [name of firm], I would like to provide comments related to potential changes in the standards of conduct of broker-dealers and investment advisers and the potential harmonization of certain aspects of the regulation of broker-dealers and investment advisers. (Release No. 34-69013; IA-3558; Duties of Brokers, Dealers and Investment Advisers)

I strongly support the Securities and Exchange Commission's (SEC) efforts to enhance retail investor protections and decrease retail investors' confusion about the standard of conduct owed to them when their financial service professional provides them personalized investment advice about securities. And as the SEC collects information and conducts its assessment of the costs and benefits of a uniform fiduciary standard for broker-dealers and investment advisers, I urge the Commission to consider several important questions regarding the application of the standard and its potential impact on retail investors.

1. A retail broker typically is charged by his/her employer with selling securities to his/her customers, which may involve proprietary products or principal transactions. In many cases, this puts the broker on the opposite side of the commercial transaction from the customer. In this type of relationship, how can the best interests of the retail investor best be protected? Would applying a uniform standard of conduct to the inherently different nature of broker and advisor relationships create more rather than less confusion for retail investors?
    
2. Some are advocating for greater disclosures as a means for retail brokers to adhere to a fiduciary standard. Consideration should be given to the fact that disclosure documents are dense and often not read by investors. Moreover, some believe that disclosure documents can create a false sense of security on the part of both retail investors and advice providers. Is more disclosure going to improve customer understanding of the type of service and standard of care they should expect?
    
3. How can it be determined whether a new standard defined by the SEC is "no less stringent than" the '40 Act, if it is not the '40 Act? How can we get to a measurable determination on that subjective assessment?

Any resolution must first and foremost consider the needs of America's retail investors. Don't they deserve to know the underlying reason why a product or investment strategy is being suggested? Wouldn't both parties be in a better position if there were clarity in that regard?

I believe that my clients benefit from the full fiduciary standard to which advisers like me must adhere. I would not want to see striving for a best interest standard diminish the unique value inherent in the adviser business model. There is room for the retail brokerage model as well as the advice model. But when it comes to providing personalized advice about securities to retail clients, customers deserve the highest standard of care.

I thank you for the opportunity to comment on this matter.

Respectfully,

http://www.sec.gov/comments/4-606/4606-3066.htm