"We support the SEC staff recommendation ... to adopt parallel rules ... establishing an over-arching fiduciary duty that is identical for brokers and advisers, but only if, as the Dodd-Frank Act mandates, it is no less stringent than the existing standard under the Advisers Act. We maintain that the fiduciary duty standard should be supported by guidance to clarify how the standard would apply to the broker-dealer business model and rules where needed. We believe that such an approach, if properly implemented, could both enhance investor protections and preserve key beneficial elements of the transaction-based broker-dealer business model."  MORE >>