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The Committee for the Fiduciary Standard Comment Letter to SEC on Duties of Brokers, Dealers and Investment Advisers (PDF)
The Committee for the Fiduciary Standard Link to more items from this source
[Opinion]
July 8, 2013

62 pages. Excerpt: "[S]ome of the assumptions made in the RFI would, if adopted, not conform to the requirement under the Dodd Frank Act that the fiduciary standard be as stringent as that found under the Advisers Act.... Under the jurisprudence of the Advisers Act, disclosure does not discharge a fiduciary's continued obligation to act in the client's best interest; much more is required of the fiduciary advisor.... [We] suggest the formation of a 'Fiduciary Board of Standards' for purposes of aiding the SEC, DOL, OCC and state securities regulators in the application of fiduciary standards... As the fiduciary standard operates as a restraint on conduct, certain business practices of brokers should be modified."

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