Subject: File No. 4-606
From: Raymond F. Unger, Mr.
Affiliation: Chairman, Forward Investment Advisors, Inc.

March 27, 2013

I strongly recommend that a full disclosure rule be adopted regarding any financial remuneration (or the value of any rewards, gifts, or credits) a financial advisor receives during an engagement with a client. By remuneration I would include any fees, commissions, rebates, hourly charges, or dealer spreads that a financial advisor receives either through his employer, or through his self-employed business.
I would also define financial advisor as anyone who provides, counsels, or sells any financial products, including insurance products (annuities), financial assets (stocks, bonds, or derivatives, etc.) or any other asset that can be included in a client portfolio (precious metals, gems, art, etc.).

I fully realize that many financial advisors would object to these disclosures but during my over 40 years in the investment business, I have found that those who most strongly object to such disclosures are the very people who have abused their privileges as a financial advisor by avoiding these disclosures.