"BICE could be misconstrued, in several respects, so as to permit over time the perverse economic incentives that result from conflicts of interest.... [We] have to view the Best Interest Contract Exemption (or BICE) as a temporary, interim measure, designed to permit the investment industry time to adjust to a true fiduciary environment. Otherwise, BICE could institutionalize best practices, particularly if it is not applied correctly in FINRA arbitration, which appears likely.... BICE's permission of differential compensation to the firm (although not to the individual advisor) presents a huge difficulty.... the DOL should set forth examples of unreasonable compensation.... the DOL should tie the receipt of compensation, in time, to the delivery of services."  MORE >>