Subject: File No. 4-606
From: Loren W Walden, CFA
Affiliation: Senior Portfolio Manager and Adjunct Professor of Ethics in Finance, University of San Francisco

March 27, 2013

Transparency into various financial service practices fosters a culture of stewardship rather than a culture often at odds with retail investor objectives. A standard of fiduciary duty applied to all professionals administering financial advice is in the best interest of the public. Practices that are misaligned with investor goals further erodes trust in our financial systems and perpetuates problems with selling product rather than investing solely in the clients best interest.

Investment professionals providing investment advice to the public should be held to a standard of fiduciary law charged with care, loyalty, skill, prudence, and diligence when investing and with clear language disclosing any conflicts of interest prior to engaging in any investment counsel.

There are many cases illustrating that the average retail investor does not understand the (currently legal yet undisclosed) tools often used in the financial services industry to enrich the manager to the detriment of the investor.

Our job as members of the investment profession is to protect the public through education and oversight by administering a uniform standard that protects unsophisticated investors from harm.