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ICI Comment Letter to OMB About Data Used in DOL Re-Proposal of Fiduciary Rule (PDF)
Investment Company Institute [ICI] 
[Opinion] Apr. 9, 2015 8 pages. "Based on documents available on the [DOL] website and on public statements ... it appears that the Department is relying as justification for the re-proposal, at least in part, on a Council of Economic Advisor's report (the 'CEA Report) ... to establish a 'compelling public need' for purposes of compliance with Executive Order 12866, and as a basis for the re-proposal's required regulatory impact analysis. Several claims made in the CEA Report call the reliability of that report into question, in particular as justification for any regulatory expansion by the Department." MORE >> |
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