Subject: File No. 4-606
From: darcy b johnson
Affiliation: Principal, Fulcrum Capital, LLC

March 27, 2013

Personally, I'm gratified that the SEC is evaluating this issue. It's way past time that all investment professionals be held to the same standard for their clients. Not every role can have access to the same level of client information. Understanding the client's objectives, experience and risk tolerance is a very important and large task. No retail sales person can have that much time to invest in each client but that doesn't mean they can't be held to the standards of prudence, loyalty and care.