The Committee on Capital Markets Regulation (CCMR) today submitted to the Department of Labor (DoL) a comment letter regarding its fiduciary duty rule proposal. The letter focuses on four principle concerns that have been raised by advisers and investors. First, the definition of “fiduciary” investment advice is far too broad. Second, the Best Interest Contract Exemption is administratively impracticable and in tension with existing regulations. Third, the compensation structures encouraged by the proposed rule would increase costs for many investors. Fourth, the cost benefit analysis lacks quantitative support and underestimates significant costs.

A PDF of the comment letter may be downloaded here.