"TC Services continues to support a uniform standard of conduct for broker-dealers and investment advisers when providing personalized advice about securities to retail customers.... [We] believe a uniform standard will benefit investors. We agree the distinctions between the suitability standard to which broker-dealers are subject and the fiduciary standard to which investment advisers are subject are not consistently appreciated and understood by investors. At the same time, we believe it is of paramount importance that the Commission establish a common understanding of the framework for such a uniform standard. We support a uniform standard which imposes a duty to act in the best interests of the customer through a duty of loyalty and a duty of care when providing advice about securities, but which also recognizes the value of episodic advice and the nature of such relationships."