SIFMA provides comments to the Securities and Exchange Commission (SEC) on the SEC study on investment advisers and broker-dealers required by the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act) Section 913.  SIFMA has supported the implementation of a new, federal fiduciary standard of care for brokers and advisers that puts customers’ interests first and preserves customer’ access to, and choice among, financial products and services.  SIFMA opposes any proposed approach that would simply impose the Investment Advisers Act of 1940 (Advisers Act) fiduciary standard on the broker-dealer business model. Such an approach would be ill-advised because the Advisers Act was not designed to regulate brokerage activity, the Securities Exchange Act of 1934 already pervasively regulates broker-dealers, and the implementation of a new harmonized fiduciary standard holds the most promise for overall better protection for retail customers, while preserving their access to, and choice among, financial products and services.