SIFMA provides comments regarding the Department of Labor’s proposed delay in the applicability date of the final rule under the Employee Retirement Income Security Act of 1974, as amended (ERISA) that redefines the term “fiduciary”, and in the applicability dates of the exemptions granted with the Rule. SIFMA strongly supports the DOL’s proposed delay and hopes our comments are helpful in pointing out why a delay is in the interest of participants and beneficiaries and other retirement investors. SIFMA argues the delay is necessary to avoid customer confusion, allow the DOL adequate time to address the questions raised in the President’s memorandum, and because the current data relied upon by the Department is flawed. Furthermore, SIFMA argues that the delay be effective the date it is published in order to avoid unintended consequences.