17 pages. "To provide needed certainty, reduce harm to investors, and limit unnecessary 'sunk' costs associated with implementing requirements that the Department ultimately eliminates or modifies, the Department should immediately ... issue an interim final rule delaying the January 1, 2018 applicability date to January 1, 2019 ... [and] announce its intent to finalize amendments to the rulemaking prior to the end of the one-year delay period. [ICI recommends] that the applicability date of any modified rule and exemptions become effective no sooner than one year after finalization -- approximately January 1, 2020."