Subject: File No. 4-606
From: Frederick Hoefert, CFA
Affiliation: Hoefert Associates

August 30, 2010

The standard for providing investment advice should be the same for brokers and advisers: to have a fiduciary obligation to act in the investor's best interest. It is what investors deserve and what they should be able to expect, and it is consistent with the CFA Institute's longstanding position and its Code of Ethics and Standards of Professional Conduct.