Client memo from Davis Polk on SEC Study on the Fiduciary Duty of Investment Advisers and Broker-Dealers. On January 21, 2011, the Securities and Exchange Commission (SEC) released its much anticipated staff study on the effectiveness of the standards of care required of broker-dealers and investment advisers providing personalized investment advice about securities to retail customers. As required by Section 913 of the Dodd-Frank Wall Street Reform and Consumer Protection Act, the Study also considered whether there are regulatory gaps, shortcomings or overlaps that should be addressed by rulemaking.