The following Letter Type D, or variations thereof, was submitted by individuals or entities.

Letter Type D:

We write to commend the Securities and Exchange Commission (SEC) for its recent rulemaking proposing standards of conduct for financial professionals. As individuals, businesses and financial market participants, we believe the SEC—with jurisdiction over all types of financial professionals and their accounts—is the appropriate agency to address relevant standards of conduct.

We believe the proposed rulemaking takes a balanced approach that builds upon the well-established broker-dealer regulatory regime and the antifraud protections under the securities laws. We were pleased to see the SEC and Chairman Clayton recognize that an important goal of this rulemaking is to further investor dialogue and spark conversation. Our overarching concern has been a reduction or elimination of commission-based brokerage services and the resulting impact on investor choice and control, which was an unfortunate result of the Department of Labors Fiduciary Rule.

While there are areas where the SEC can provide additional clarity, guidance, and certainty for firms seeking to comply with this heightened standard, we encourage the SEC to finalize this long-anticipated rulemaking. We are confident that a final rule will promote investor understanding and choice, maintain appropriate flexibility for firms and investment professionals, and adhere to the SECs long-standing and effective disclosure regime.

We strongly support the rulemakings codification of a best interest standard based in part on the current FINRA suitability standard, and its principles-based, facts and circumstances approach. We do not believe that a broker-dealer must be labeled as a fiduciary in order to be held to an equally stringent standard. The SEC rightfully recognized the unique characteristics of the broker-dealer business model and sought to preserve it in this rulemaking.

We appreciate the SECs diligent efforts in putting forth this proposal, which will provide a national standard rather than conflicting state standards. We thank the SEC for the opportunity to comment during this important process.

http://www.sec.gov/comments/s7-08-18/s70818-typed.htm