Subject: File No. 4-606
From: David nowacki
Affiliation: professor of finance financial and strategic consultant

September 7, 2010

-It is in the best interest of financial advisers, stock brokers and retail finance salespersons to make the 'investment process' as complex as possible in order to make customers rely upon them for advice and guidance.
Since the SEC and industry DOES NOT REQUIRE FULL DICLOSURE for all relevant information, consumers have no place to trust for pure facts. For example, finance professionals claim certain 'average returns' for the stock market components when academic studies cannot verify such information. Furthermore, the industry allows SURVIVAL BIAS TO REMAIN as a cornerstone in the industry.

At minimum, the SEC should require all data to be used if anyone quotes any average return....otherwise you are saying Babe Ruth hit you only count "at bats against right months with even numbers.....on odd days...with left handed pitchers with red hair

ALLOWING the distortion of data with the use of survivor biased data is a fraud....continually allowed by your agency

This practice needs to stop.