"Descriptions of an investment's or distribution option's characteristics, including the pros and cons of selecting that investment or distribution option, should be included within the investment education carve-out.... It is critical that the Department allow existing clients to be grandfathered under current rules, particularly if the Department does not provide for a transition period of at least thirty-six months.... We remain concerned about the Department's adoption of FINRA's definition of 'recommendation,' especially if the Department incorporates the entire FINRA rule and accompanying guidance ... It is appropriate to expand the platform provider carve-out to IRAs because the carve-out only provides relief for marketing a platform of investments."