"We support the SEC staff's recommendation to adopt an over-arching fiduciary duty for investment advisers and broker-dealers if, as mandated by the Dodd-Frank Act, it is no less stringent than the existing standard under the Advisers Act. To achieve this, it is important that a uniform fiduciary duty standard, when promulgated, contain both the rules and practical guidance to clarify how the standard would apply to the broker-dealer business model."  MORE >>