Subject: File No. 4-606
From: Stephen G DeTommaso, CFA
Affiliation: Managing Director, Investment Analytics, AIG Asset Management

March 27, 2013

As a CFA Charterholder, I support a single fiduciary standard for any individual selling securities or any type of investment product. It is important that any firm or professional in role of recommending or selling investment products to an institution or individual meet a fiduciary standard. This is not about fairness or equality or an even playing field for the professionals recommending or selling investment products. Instead, this is about avoiding conflicts of interest that can result in the recommendation or sale of products that may be suitable on a stand-alone basis, but sub-optimal from perspective of the complete financial position of the buyer. Sub-optimal includes considering the cost of the products relative to competing alternatives that achieve similar objectives and results, overall cost/benefit, and risk to the buyer on both a stand-alone and overall financial position/portfolio perspective.