Date: July 20, 2015

Issue: Fiduciary Duty

To: U.S. Department of Labor

Filing Type: Regulatory 

Description: The Department of Labor's Notice of Proposed Rulmaking Regarding the "Definition  of the Term 'Fiduciary'; Conflict of Interest Rule- Retirement Investment Advice". These comments address the adequacy of the regulatory economic analysis that is presented by the Employee Benefits Security Administration (EBSA) as the basis for the specific proposed rule and proposed Prohibited Transaction Exemptions (new and amended) presented in EBSA's proposed rulemaking notices. 

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