"The great debate over a fiduciary standard for retirement advice, now in its fifth year, is about to enter its final, climactic phase. In the meantime, the Department of Labor has entered a self-imposed blackout to review feedback on its proposed conflict of interest rule. DOL is legally constrained from discussing any specific changes in advance, but this article offers an analysis based on specific issues that key supporters and some opponents agree need revisions; and on other, recent remarks by senior DOL officials suggesting that they are open to change in certain areas of the proposal."