July 2, 2015

Via Online Submission 

Office of Regulations and Interpretations 

Employee Benefits Security Administration 

Attn: Definition of Fiduciary Proposed Rule 

Room N–5655 

U.S. Department of Labor 

200 Constitution Avenue, NW. 

Washington, DC 20210 

Re: BetterInvesting support and commentary on RIN 1210-AB32

Greetings:

BetterInvesting, a 501(c)(3) non-profit investment educational organization, 

appreciates the opportunity to comment on RIN 1210-AB32, the proposed 

amendment to 29 CFR 2510.3-21(c). BetterInvesting fully supports the amendment 

proposed by the Department of Labor.

By way of background, BetterInvesting was founded in1951 to help educate and 

provide materials and a methodology to Americans so they might learn how to build 

wealth by participating in the growth of the American economy through long-term 

ownership in the stock of public companies. BetterInvesting is believed to be the 

oldest and largest non-profit investor education organization in the nation. Over a 

60+ year period, BetterInvesting has provided investment education to millions of 

US citizens.

BetterInvesting’s Individual Investor Advocacy Committee is chartered to educate, 

guide and support BetterInvesting’s public policy advocacy role that befits its role as 

the largest non-profit membership organization for individual and club investors in 

the US.

Given that most of our membership base owns the type of retirement accounts 

covered by the proposed Rule, we agree that it is a high priority and in the best 

interest of our membership to support the proposed rule and its intent. 

BetterInvesting members hail from a wide spectrum of income and wealth 

levels. One of our core beliefs is that saving and investing even a small amount of 

money monthly, ideally starting at a young age, can yield retirement nest eggs that 

substantially enhance the well being of retirement for all Americans across all 
income levels. This has been proven countless times over the years. BetterInvesting 

is supported by over 1,000 volunteers nationwide who give generously of their time 

and talent, without compensation, to educate the population at large on the benefits 

of regular saving and investing.

It is our belief that the proposed Rule and its intent helps to better define the term 

fiduciary and make sure that said fiduciaries are held to the highest standards of 

conduct when advising those in retirement plans as well as maintaining the best 

interests of the asset owner in all investment advice. In other words, the Rule 

provides needed protection from paid advisers who put their own interests and 

compensation above those whom they are advising, creating a huge conflict of

interest. The impact of this Rule should help to assure investors that the advice and 

recommendations they are given are in their best interest (ethically and) financially,

and hence should lead to better investment results over time. For the above 

reasons, BetterInvesting supports the proposed Rule.

In addition, BetterInvesting believes that it is time for both the SEC and FINRA to 

establish the appropriate standard of care for brokers and dealers. Specifically, 

when recommending a security or strategy to retail investors, broker-dealers be 

required to ensure that the recommendation is in the “best interest” of the investor.

We appreciate the Department of Labor’s consideration of our comments. Please 

feel free to contact us if we can provide any additional information to assist.

Best Regards,

 

Kamie Zaracki Roger Ganser Robert Brooker

Chief Executive Officer Chairman Committee Chair

 

John Gannon Julie Werner Allen Holdsworth

Committee Member Committee Member Committee Member

CC: Mary Jo White, Chair, Securities and Exchange Commission

Rick Ketchum, CEO, FINRA