Subject: File No. 4-606
From: Scott D Horsburgh, CFA
Affiliation: Seger-Elvekrog Inc., president

March 27, 2013

I support a single standard for those providing similar services. I see the primary distinction as the form of compensation and feel that there needs to be truth in labeling. There should be a clear label for a broker who sells investments for a commission. The suitability standard would still work here. However, re-labeling a broker as an "investment consultant" or "financial consultant" implies a neutral relationship and should not be allowed. An investment advisor should be held to a fiduciary standard and compensated only by the client.