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Weighing In at the SEC

Sigma Investment Counselors

April 9, 2013

Sigma Investment Counselors President and CEO, Bob Bilkie, CFA, recently submitted the following in response to the US Securities and Exchange Commissions’ Request for Comment regarding Duties of Brokers, Dealers, and Investment Advisers for those providing investment advice (Release No. 34-69013; IA-3558; File No. 4-606).

Thank you for providing a comment period pursuant to your anticipated action related to standards of conduct for those providing investment counsel/advice to clients. As an SEC Registered Investment Advisor and a CFA charterholder, I have wholeheartedly embraced the notion of a fiduciary standard, feeling that this is the best way to serve clients. I have seen many instances of what I would label abuse by advice providers operating under a “suitability” standard during my nearly 30-year career. The end client does not recognize the differences between advisors operating under a fiduciary standard versus a suitability standard. They lack the sophistication. As a result, I have long supported consistent treatment of all individuals and firms engaged in similar activities. I believe that brokers who provide personalized investment advice to their retail clients should have to adhere to a fiduciary standard of care similar to that which currently applies to investment advisors.

Comments and questions welcome.

Bob Bilkie, CFA

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