"Disclosure of this conflict of interest, and after-the-fact rationalization that the advice was nevertheless in the best interest of plan participants, will engender endless litigation. The securities industry has the resources to stoutly defend its position, likely leaving plan participants no better off than they were before enactment of the fiduciary rule. A true fiduciary would be prohibited from having its integrity compromised by receiving payments from anyone other than the plan sponsor (who could delegate all or a portion of these expenses to the plan participants)."