Subject: File No. 4-606
From: Michael Walther
Affiliation: CPA/PFS, CFP, CFA

March 27, 2013

Any investment professional with discretionary authority to manage money for an individual should do what is in the best interest of the individual, period. The idea that better disclosures will solve the problem is flawed. Multiple consumer surveys have indicated that the public makes no disctinction between broker/dealers and registered investment advisors (RIAs) who are held to a fiduciary standard. The public has further acknowledged that they want to eliminate or minimize conflicts of interest. Rather than trusting that disclosure of conflicts of interest will meet the public's needs, an elimination of the double standard will get all advisors on a level playing field and go a long way toward restoring the trust in our profession that the conflicts of interest have destroyed.