"Select issues with the proposal: [1] Proposal will likely result in continued regulatory uncertainty ... [2] No carve-out for transactions with sophisticated institutional investors ... [3] Fiduciary adviser status may result from others' discretion over unrelated assets ... [4] Fiduciary adviser status may result from one time advice ... [5] Fund sponsors and other investment product providers may be deemed fiduciaries by virtue of selling activities or even recommendations by third parties ... [6] Lawyers, accountants, and consultants may be deemed fiduciaries based on regular provision of investment-related legal, tax and other advice traditionally viewed as non-fiduciary.'

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