Subject: File No. 4-606
From: Rozanna Patane
Affiliation: Rozanna Patane Financial Advisor

July 5, 2013

I'm writing in support of applying one true fiduciary standard to everyone who gives financial advice to individual investors and to retirement plans.

I've been a fee-only financial advisor for over 20 years. Whenever I've explained that as a fiduciary I'm obligated to place my clients' interests first, but that not all advisor are held to this standard, people are shocked. It seems basic and obvious to them that any client would simply expect such a standard. The fine distinctions between brokers and advisors are completely lost on individual investors, and for good reason: they make no sense and exist only for the profit of those not held to a fiduciary standard.

For such a crucial and complicated aspect of managing life, the client is usually in a position of having to trust the advisor -- if she or he could do it themselves, they wouldn't be consulting an advisor in the first place.

It's as shocking to think that an advisor would act against a client's interest in such a dependent relationship as it would be in a doctor-patient relationship. We'd never consider a standard adequate that would permit a doctor to tell a patient to take a certain drug or have a certain surgical procedure because it serves the doctor but not the patient.

We should tolerate no less a standard in financial advice, if we are ever to achieve a true professional status.

This is obvious to individual investors it should be obvious to decision-makers at the SEC. Everything else is obfuscation.


Rozanna Patane