The Consumer Federation of America (CFA) opposes the current proposal to extend for another two years a “temporary” rule that provides broker-dealers that operate non-discretionary fee-based accounts with an alternate means of complying with the Investment Advisers Act’s principal trading rules. As we have previously stated, CFA believes it is possible to relax the Act’s principal trading restrictions in a way that is consistent with the protection of investors. Indeed, the Advisers Act rules have in our view been rendered obsolete by changes in the market and are themselves in need of review and revision. However, as we noted when this rule was first issued as an interim final rule in 2007, we are not convinced that the current regulatory approach provides adequate protection against abusive principal trades. The primary question that ought to concern the Commission is whether the rule prevents principal trades that are disadvantageous to investors. But that is a question that the Commission appears never to have fully considered in its ongoing reliance on a temporary rule adopted in haste without adequate opportunity for public input.