Subject: File No.
From: Joshua Lannik
Affiliation: Teacher

June 6, 2017

There is absolutely no reason why any investment adviser or broker-dealer should be held to any standard other than a fiduciary standard. Advisers should be working in the interest of their customers. If a doctor were to recommend additional, unnecessary procedures in order to boost their bottom line, we would call that malpractice. If a lawyer spends excessive amounts of time doing things that don't have a high likelihood of benefiting their clients, we'd call that malpractice. Non-fiduciary standards for advisers are a sort of malpractice as well the average investor has no idea that their adviser can recommend investments that benefit the adviser more and the investor less. That's obscene, and it needs to stop, particularly for ERISA plans where investors have no direct control over the scope of the funds available or the price or choice of the advisers available.