Framework for Rulemaking Under the Fiduciary Duty Provision of the Dodd-Frank Act

SIFMA provides a supplemental filing to the Securities and Exchange Commission (SEC) on developing a framework for rulemaking under Section 913 (Fiduciary Duty) of the Dodd-Frank Wall Street Reform and Consumer Protection Act (Dodd-Frank Act), File No. 4-604.  SIFMA responds to several points raised in a recent letter from the Consumer Federation of America (CFA), among others, that discusses SIFMA’s July 2011 framework for rulemaking under Section 913. SIFMA describes key similarities in its views and those expressed in the CFA Letter and key differences between those views with the hope in developing an approach to Section 913 that best protects investors and preserves investor choice.