"The [Best Interest Contract (BIC)] will be a formal contract committing the advisor and her firm to act with the care, skill, prudence and diligence that a prudent person would exercise based on the circumstances.... This is a roadmap for the plaintiffs bar as prudent persons can disagree on what is prudent in various circumstances, and reasonable fees may be reasonable to some and not to others.... The firm must warrant that it has adopted policies and procedures designed to mitigate conflicts of interest.... Going through the process to 'clean up' will be expensive as well and will likely require significant changes in the way many firms do business.... There are required disclosures that must met in the BIC ... This will add significant additional cost to the process.... Being unable to limit exposure may be cost prohibitive when it comes to small plans and small accounts."