SIFMA provides comments to the Securities and Exchange Commission (SEC) on data and information to help inform two SEC inquiries: (i) whether to establish a uniform fiduciary standard for broker-dealers (BDs) and registered investment advisers (RIAs); and (ii) whether to pursue broader harmonization of BD and RIA regulations, SEC Release No. 34-69013; IA-3558; File No. 4-606. SIFMA has long supported a uniform fiduciary standard for BDs and RIAs when providing personalized investment advice about securities to retail clients, while advocating for broader harmonization of BD and RIA regulations.

SIFMA shares it’s general views on the appropriate cost-benefit approach for analyzing a prospective fiduciary standard; the problems associated with applying existing Advisers Act guidance and precedents under Section 206 to BDs; and also presents new data gathered through a survey of SIFMA’s BD members pertaining to certain specific costs likely to be incurred by BDs in implementing the uniform fiduciary standard.