Bogle Financial Markets Research Center John C. Bogle, President P.O. Box 2600, V22 Valley Forge, PA 19482 Via Electronic Submission
[email protected], File Number 4.606 July 2, 2013 Re: File Number 4-606, Duties ofBrokers, Dealers, and Investment Advisers To: Securities and Exchange Commission, Washington, DC I am the founder (in 1974) of The Vanguard Group oflnvestment Companies (all of which are open-end funds registered under the Investment Company Act of I 940), serving as chief executive from 1974 to 1996; the creator of the first index mutual fund in 1975; the President (since 1999) of Vanguard's Bogle Financial Markets Research Center; and author often books focused largely on the mutual fund industry. I am writing on my personal behalf in support of establishing a uniform standard of fiduciary duty for brokers, dealers, and investment advisers, including advisers to mutual funds. My views do not necessarily reflect the views of Vanguard's present management. I am well aware that SEC Release No. 34-69013 is focused on investment advisers "providing personalized investment advice about securities." But as paragraph I.4. of the staffs discussion notes, in paragraph two, "all investment advisers are fiduciaries to their clients." The amounts of assets advised for clients (shareholders) ofmutual funds are nearly ten times the assets advised ($12 trillion vs. $1.5 trillion) by firms providing personalized investment advice. To focus on the latter group to the exclusion of the much larger former group would leave a yawning gap in SEC regulation that would ill-serve fund investors.