"It sounds like advisors to small plans (under 100 participants) would sign a BICE contract, but they still can get indirect compensation like 12-b1 fees. Wouldn't this be in conflict with putting the participant interests first? ... How do we get ahead of this -- regardless of outcome? ... If I only receive level comp from plan sponsors or IRAs and sell no proprietary products, I would not be subject to a BIC requirement? ... How would you respond to those who say this rule will reduce access to services to the middle income savers?"