Subject: File No. 4-606
From: Christopher Gerber

April 2, 2013

Release No. 34-69013 IA-3558 File No. 4-606
Duties of Brokers, Dealers, and Investment Advisers AGENCY: Securities and Exchange Commission.
ACTION: Request for data and other information.

There should not be uniform rules unless there are uniform and high standard licensing requirements to offer investment advice to retail clients. Currently the licensing requirements are minimal and there is non rigorous continuing education required. In a business easily as complex as medicine, the comparative requirements to offer investment and medical advice are highly disparate. This should change before attempting regulation that will only make more rules and fill the regulators' pockets with more fees. Getting everyone on the same body of knowledge first, then evaluating the regulation is the proper way to proceed. I recommend that all retail advisors be required to complete something like the CFA exams successfully before being allowed to provide retail advice.