After many readings, we conclude that the department did little in the way of improving the unworkable and harmful aspects of the proposed rule and, instead, spent much of their time (and words) defending their definition of
fiduciary, why they included IRAs and what they believe
constitutes investment
advice.
The information provided does not
constitute a recommendation of any investment strategy or product for a particular investor and should not be considered
advice given in a
fiduciary capacity, including within the meaning of ERISA.