Subject: File No. 4-626
From: Ken Kivenko
Affiliation: Investor Advocate

April 20, 2011

Submission to SEC Investor Education Request for Comments

As to financial literacy ,the key points are definition of financial terms, basic algebra, compound interest and
discussion of each product. We'd put mortgages, credit cards, pensions and mutual funds / investment funds at
the top of the list. This has to start in the schools. For us , an important element is to teach people how to avoid outright scams, toxic financial products and commission -driven "advisors".The annual losses are staggering.

People need to be taught to be less trusting and more inquisitive about financial products and services.
For example, we have high mutual fund fees because the public is too trusting and doesn't
realize all the fees,/ commissions built in and the impact these expenses have on returns over the long term. This is
taking a very heavy toll on retiree and pensioner nest eggs.

Today's financial products are increasing in complexity so financial consumer protection is paramount. No
amount of financial literacy will be able to keep pace with the creativity of the financial services industry .A fiduciary standard needs to be applied to all those holding out the shingle of Advisor. This need to be coupled with an effective fair , low-cost complaint resolution system.

A terrific amount of work was recently done on the financial literacy issue in Canada . The FINAL Report can be found at

One caution: There is a great danger that the literacy initiative will result in a retardation in regulatory reform. That would be a big mistake.


Ken Kivenko P.Eng.
Kenmar Associates
Toronto, Canada