Subject: File No. S7-07-18
From: Robby W Morris

June 21, 2018

Our nation has largely moved to a retirement system where individuals are more and more dependent upon their own savings or employer offered savings plans (e.g., 401Ks, 403Bs, etc). Although people have been essentially forced into this system via elimination of defined benefit pensions, the vast majority of individuals have no knowledge and no education or aptitude for investing their retirement savings wisely. This clearly mandates the government, if operating in the best interests of its citizens, implement and enforce a uniform fiduciary standard of conduct for broker-dealers and investment advisers when providing investment advice about securities to retail customers or employees being offered securities via employer sponsored retirement savings plans. The standard would require firms to act in the best interest of the customer without regard to the financial or other interest of the broker, dealer or investment adviser providing the advice. Firms would not be allowed to only meet a suitability standard which leaves open a wide berth for conflict of interest.