SIFMA provides comments to the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor on a proposal to make changes to the Employee Retirement Income Security Act of 1974 (SIFMA) that would provide additional guidance on the statutory exemption for investment advice, and the proposed class exemption for investment advice that does not meet the statutory exemption. SIFMA strongly supports the class exemption, without which the hurdles to providing investment advice are too high. However, SIFMA questions some of the audit requirements, scope of fee leveling, disclosure requirements, as well as other provisions.