Subject: File No. 4-606
From: Stefan Whitwell, CFA, CIPM
Affiliation: CEO, Empirical Solutions, LLC

March 27, 2013

As a risk-management professional, I see examples all the time where so-called investment advisors and investment consultants are busy selling financial services and products in the context of multiple conflicts of interest -- so much so, that nobody is actually helping the clients ask the key questions they should be asking about risk and process and conflicts. Clients deserve to have their interests come first -- especially when there is an unequal relationship in terms of experience and resources between the parties in a transaction. If business is done with the client's needs in mind, then having a duty to abide by a fiduciary duty should be easy to comply with and merely serve to remind us that in the long run, we all do better when doing right by others. Harmonizing the rules so that all investment advisors and brokers need to abide by the same standard of care owed to the client makes a lot of sense and is something that we support.

(Attached File #1: 4606-3019a.pdf) (Attached File #2: 4606-3019b.pdf) (Attached File #3: 4606-3019c.pdf)