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Response to DOL Definition of Fiduciary IRA Data Request (PDF)
Financial Services Institute [FSI] 
[Opinion] Feb. 28, 2012
The data request suggests that the Department could draw conclusions -- sufficiently reliable to base an enormously consequential regulation like the ERISA fiduciary definition -- about the 'impact, if any, of conflicts of interests faced by brokers or other[s] who advise IRAs ... on IRA investors' from investment returns or trading histories in IRA accounts, analyzed against a (unavoidably, select and less than comprehensive) range of variables. [FSI] respectfully disagree[s][.]
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