"[T]he SEC's proposal is not actually a uniform standard that would require brokers to be fiduciaries, but instead would only partially lift the conduct standards for broker-dealers, with a new 'Regulation Best Interest' requirement that would obligate brokers to act in the best interests of their customers when making an investment recommendation ... but only at the time they actually make the recommendation. And not at all if the broker is implementing recommendations that were crafted while wearing his/her investment adviser 'hat' under a dual-registered B/D-RIA firm."