Subject: Proposed Fiduciary Rule
From: Elizabeth Copley

April 24, 2017

As a long-time Securities Arbitrator, I am fairly familiar with broker-dealer practices.  Thus, may I suggest a very simple solution to subject.  Broker dealers have long established guidelines for handling Trust accounts that are very familiar to their financial advisors.  It would be very simple to administratively code all IRA'S and 401 (K-s) as Trust accounts, which is logically consistent anyway.  This would automatically  have these accounts handled in a regulated and conservative manner (eg. no options etc.), and it would also forestall the plethora of lawsuits likely to follow each individual broker deciding on appropriateness of specific actions.  

Hope this helps,
Elizabeth A. Copley, Esq.