SIFMA Comments on Massachusetts Fiduciary Rule Proposal

Washington, D.C., July 26, 2019 – In a comment letter submitted today regarding a Massachusetts proposal to create a state-level fiduciary standard, SIFMA expressed strong concern with the potential negative impact such a standard would have on investors and urged the state to defer to the new nationwide best interest standard finalized by the Securities and Exchange Commission (SEC) last month.

“Limiting access to critical financial education, advice and guidance has a substantial negative impact on consumers.  We believe that this proposal limits access by imposing additional fiduciary requirements that will result in further constriction of the brokerage model,” SIFMA wrote in the letter. “Consumers will be adversely affected by the limitations placed on programs available to them, the pricing of those programs, and the investment products available – which could include losing access to personal, one-on-one assistance.  Substantial inconsistencies between the federal standard and the proposed Massachusetts rule will also create confusion for consumers and financial professionals and come with significant operational and compliance costs.”

“We would encourage Massachusetts to allow Reg BI to be fully implemented before moving forward with a state-specific fiduciary rule,” the letter continued. “We believe that once Reg BI is fully operational and the SEC, FINRA and state regulators begin examining for compliance, the Division will find that Massachusetts investors are receiving substantial additional protections while continuing to have access to the numerous choices and opportunities they have today.”

SIFMA’s full comment letter further details these views and outlines recommended changes:

SIFMA also joined with eleven other financial services trade associations in a letter echoing these concerns, which can be found here:


SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA). For more information, visit