Subject: File No. 4-606
From: Joe Almon, CFA

March 30, 2013

Clearly, a fiduciary standard is better for those receiving investment advice than for those providing it. Since there is no difference whatsoever in the role of an advisor at a broker dealer and one at a fee-only Registered Investment Advisor (I have worked for both), except for juxtaposition in the priority-of-interest the client occupies, it's clear that, to date, the clients' interests have finished second to those of broker dealers' via the SEC's policies. I am writing to encourage you to change this once and for all. As a CFA charterholder, I fully support the CFA Institute's position as stated below.

"We have long supported consistent treatment of all individuals and firms engaged in similar activities. For this reason, we believe that brokers who provide personalized investment advice to their retail clients should have to adhere to a fiduciary standard of care similar to what currently applies to investment advisers. This position is supported by survey responses from CFA Institute members who overwhelmingly support a single fiduciary standard for those who provide personalized investment advice, regardless of job description."

Best regards,

Joe Almon, CFA