Improving Investment Advice for Workers and Retirees

Published on:
September 3, 2020

Summary

Written testimony for Kevin Carroll, Managing Director, and Associate General Counsel at SIFMA appearing before the U.S. Department  of Labor, Employee Benefits Security Administration at the hearing on Improving Investment Advice for Workers and Retirees

Excerpt

TESTIMONY OF KEVIN CARROLL

MANAGING DIRECTOR AND ASSOCIATE GENERAL COUNSEL,

SECURITIES INDUSTRY AND FINANCIAL MARKETS ASSOCIATION

BEFORE THE U.S. DEPARTMENT OF LABOR,

EMPLOYEE BENEFITS SECURITY ADMINISTRATION

HEARING ON: IMPROVING INVESTMENT ADVICE FOR WORKERS AND RETIREES

SEPTEMBER 3, 2020

Good afternoon. I am Kevin Carroll, Managing Director and Associate General Counsel at the Securities Industry and Financial Markets Association. SIFMA represents the interests of hundreds of broker-dealers, investment banks and asset managers.

We appreciate the opportunity to further comment on the Department’s proposed exemption.

First, let me express SIFMA’s strong support for the Department:

Replacing the vacated 2016 investment advice rule and reinstating the original five-part test;

Reinstating Interpretive Bulleting 96-1; and

Reinstating the class exemptions that were part of the same 2016 initiative, as they existed prior to 2016.

Directionally, SIFMA also supports the Department’s proposed exemption to the extent that:

It permits financial professionals to provide investment advice in a flexible manner; and

It is aligned with the SEC’s Regulation Best Interest (“Reg BI”).

Accordingly, SIFMA urges the Department to proceed without delay to finalize its new protections for retirement savers, while at the same time ensuring that those same investors receive the benefit of a consistent best interest standard across both the DOL and SEC regulatory regimes.

Continue Reading > 

Details

Download

More Content

  • Amicus Briefs
    Oct 05, 2026

    In re The Boeing Company Securities Litigation

  • Letters
    Oct 05, 2026

    Reducing Duplicative Regulation and Expanding Exemptions for Commodity Pool Operators and Commodity Trading Advisors

    SIFMA AMG comments on CFTC proposals to reduce duplicative regulation for certain CPOs and CTAs and account for inflation.
  • Letters
    Sep 30, 2026

    Proposed Rule Change to Amend FINRA Rules 0150, 2165, 4512 and to Adopt FINRA Rule 2166

    SIFMA Comments to SEC in support of the proposed rule changes to improve the utilization of Rules 2165 and 4512, as well as the new Rule 2166 to allow for a temporary delay for suspected fraud.

Get the latest trends, stats, and research on financial markets and securities.