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Financial Services Institute Comment Letter to SEC on Duties of Brokers, Dealers and Investment Advisers (PDF)

45 pages. Excerpt: "FSI's members are committed to a regulatory environment that achieves three important goals: (1) Investor access to financial advice and services; (2) Investor choice between available providers of advice and services; and (3) Robust and effective investor protections. FSI and its members believe that a uniform fiduciary standard of care, plainly articulated conduct rules, effective customer disclosures, and balanced regulatory supervision efforts will achieve all three of these goals and promote an environment that provides widespread benefits to all stakeholders."

Financial Services Institute Comment Letter to SEC on Proposed Money Market Reforms (PDF)

"In general, [FSI remains] opposed to additional MMF reforms. While the SEC's arguments in favor of reform appear to be well-researched, FSI finds them ultimately unpersuasive. In addition to the increase in operational costs to investors, funds, and intermediaries, the SEC has inadequately addressed the widespread disruption likely to occur in the wake of additional regulations[.]"

DOL Fiduciary Rule Price Tag: $3.9 Billion for Independent Financial Services Firms

"The study estimates the DOL's proposed rule will cost the independent financial services industry and investors nearly $3.9 billion in total startup costs to implement the rule -- nearly 20 times DOL's preferred cost estimate. This amount does not take into account the cost of investors' lost access to advice or the ongoing costs of maintaining compliance with the rule.... The proposed rule will result in estimated startup costs ranging from $1.1 million to $16.3 million per firm, depending on firm size.... The proposed rule will result in industry consolidation likely to force small broker-dealers out of business." [Also available: an executive summary (6 pages) and the full text of the study (39 pages).]

Poll Shows Growing Financial Advisor Opposition to DOL Fiduciary Rule

"Financial Advisor opposition to the Department of Labor's fiduciary definition proposal has increased over the past year. This latest poll found that 91% oppose redefining the definition of fiduciary for financial advisors, up from 89% in August and 72% in February of this year. The redefinition would ban the earning of a commission on IRA advice, pricing millions of middle class investors out of the market on affordable advice."

Response to DOL Definition of Fiduciary IRA Data Request (PDF)

The data request suggests that the Department could draw conclusions -- sufficiently reliable to base an enormously consequential regulation like the ERISA fiduciary definition -- about the 'impact, if any, of conflicts of interests faced by brokers or other[s] who advise IRAs ... on IRA investors' from investment returns or trading histories in IRA accounts, analyzed against a (unavoidably, select and less than comprehensive) range of variables. [FSI] respectfully disagree[s][.]

SEC Describes Exam Priorities for 2014

"Some items that will be of particular interest to independent broker dealers and their registered reps include the SEC taking a close look at: [1] Supervision conducted by large branch offices and independent firms; [2] Supervision of financial advisors located in remote locations; [3] The suitability of IRA rollovers; [4] Dual registrants and the potential conflicts of interest that could exist within that business model; and [5] The suitability of variable annuity buybacks."

Proposed Senate Resolution Would Recognize Importance of Preserving Tax Incentives for Retirement Savings

"A new Senate resolution hoping to at least recognize the long-term importance of tax-deferral incentives for retirement savings -- 'low-hanging fruit' in this time of 11th-hour fiscal cliff budgetary wrangling -- is making the rounds in Washington, with some extra support from the retirement industry.... The resolution, a 'Sense of Congress' statement, reiterates that current tax incentives for retirement savings do indeed provide important benefits for Americans, as well as actually providing the impetus for workers to help prepare for their own retirement -- in the absence of any other nationalized retirement or pension plan, other than Social Security."