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NAPA Comment Letter to SEC on Duties of Brokers, Dealers and Investment Advisors (PDF)
National Association of Plan Advisors (NAPA) Link to more items from this source
[Opinion]
July 5, 2013

"The Commission should not implement the Staff's recommended 'uniform fiduciary standard' for broker-dealers and investment advisers because such a standard would effectively result in a non-uniform 'uniform fiduciary standard' leading to significantly increased confusion for retail customers when selecting an Investment Professional.... The Commission should instead require Investment Professionals to provide retail customers with clear and concise pre-engagement disclosures designed to assist retail customers in the selection of Investment Professionals.... The Commission should take the lead to ensure that consistent disclosures are provided by Investment Professionals to protect retail customers' access to investment advice, regardless of the method by which their investment accounts are taxed."

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