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.