13 pages. "The Proposal is truly unprecedented in that the Department proposes to use its regulatory authority to regulate the IRA marketplace and require providers to meet compliance requirements that are more demanding than currently required under the Code and, arguably, more demanding than those currently required under federal and state securities laws and state insurance laws. While the definition of 'investment advice,' the BIC Exemption, and the changes to the PTEs are only proposed and the Department must sift through hundreds of comments letters and three and a half days of hearing testimony, the Department is motivated to produce a final rule and has White House support.... Application of the final rule to IRAs should be expected."

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