Subject: File No. 4-606
From: Robert M. Bilkie, CFA
Affiliation: CEO, Sigma Investment Counselors

April 1, 2013

Thank you for providing a comment period pursuant to your anticipated action related to standards of conduct for those providing investment counsel/advice to clients. As an SEC Registered Investment Advisor and a CFA charterholder, I have wholeheartedly embraced the notion of a fiduciary standard, feeling that this is the best way to serve clients. I have seen many instances of what I would label abuse by advice providers operating under a "suitability" standard during my nearly 30 year career. The end client does not recognize the differences between advisors operating under a fiduciary standard versus a suitability standard. They lack the sophistication. As a result, I have long supported consistent treatment of all individuals and firms engaged in similar activities. I believe that brokers who provide personalized investment advice to their retail clients should have to adhere to a fiduciary standard of care similar to that which currently applies to investment advisors.