Subject: File Number S7-09-18
From: Don Lozier

April 20, 2018

I wanted to share my comments on the Proposed Commission Interpretation Regarding Standard of Conduct for Investment Advisers.  I firmly believe anyone providing financial advice to their clients should have a fiduciary responsibility to that client.  Lawyers, Real Estate Brokers, Doctors, and some CPAs are held to this responsibility and so should Financial Advisors.  The American public should know anyone helping them with financial transactions are doing what it is the best interest of the client.  If there is any daylight between the best interest and conflicts of interest, it needs to be fully disclosed in plain English.  I do not understand why we currently have 2 standards of conduct.  Having 2 standards is confusing and will become more confusing if this rule is not strengthened.  Having 2 titles of professions, brokers vs advisors, is more confusing to the public than it needs to be.  The medical profession has different types of individuals treating their patients such as D.O., M.D., and Nurse Practitioner.  All of them have fiduciary duties to their patients.  Why should the financial industry be any different?