Subject: File No. 4-606
From: Leonard M Golub
Affiliation: Financial Advisor, MBA, CFA

March 28, 2013

A complete standard of fiduciary care already exists for investment advisors (those regulated by the 1940 Act) and involves three main principles:
1. Client interests must come first
2. Conflicts of interest must be disclosed
3. Prudent management must be provided

Any uniform standard must include these time tested principles, and there must be no "watering down" of the standards by the brokerage lobby. If the brokerage industry wishes to submit to these honorable standards, then it may do so at any time.

However, if it does not, then the SEC should take immediate steps to standardize designation of advisors for the benefit of the public, which has become confused as to which standards of care apply. In this case, brokers should not be permitted by SEC to use the term "advisors" and should be known by regulation to the public as "brokers", while "advisors" remains a term reserved for fiduciaries under the 40 Act.