Subject: File No. 4-606
From: Dennis Radliff
Affiliation: Member of the American Academy of Actuaries, and a Chartered Financial Analyst

March 27, 2013

I believe, as the CFA Society stated, that "adopting a single, definable, and enforceable standard of care" is critical. Retirement savings are of the utmost importance to the American people, and many citizens get no advice, or worse, bad advice. Since many companies are moving away from defined benefit plans to defined contribution (e.g. 401(k), IRAs, etc.), the burden is on each individual to plan properly for his or her retirement. Currently, 401(k) plans underperform against pension plans, so individuals must not be getting good advice. This has to change if companies are going to continue the trend of putting the investment burden on individuals.