SIFMA provides supplemental comments to the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) on the DOL’s proposed regulation under the Employee Retirement Income Security Act of 1974, as amended (ERISA) that will redefine the term “fiduciary.” SIFMA testified during a DOL hearing on the definition of fiduciary on March 1, 2011.  This supplemental comment will respond to the questions the DOL posed during the hearing and respond to certain comments made by others who testified.  SIFMA filed its first comments concerning the Department’s proposed definition of fiduciary on February 3, 2011.