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SIFMA Comment Letter to SEC on Recommendations of the Investor as Purchaser Subcommittee on Broker-Dealer Fiduciary Duty (PDF)
Securities Industry and Financial Markets Association [SIFMA] Link to more items from this source
[Opinion]
Oct. 17, 2013

"[T]he Subcommittee (and indeed, the Committee) does not have a single broker-dealer representative. A representative from our industry could provide the necessary perspective to help generate more practical, consensus-based recommendations that would benefit all parties, but most particularly retail investors.... Section 913 should be implemented through rulemaking under the Exchange Act for broker-dealers.... [This] rulemaking should require broker-dealers to provide customers with uniform, plain English disclosures.... Section 913 should not be abandoned in favor of an approach that Congress considered and rejected -- namely, tinkering with the broker-dealer exemption."

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