CFA appreciates the opportunity to comment on an issue that we believe is central to improving protections for unsophisticated investors in their dealings with sometimes predatory and often self-interested financial professionals. We are encouraged that the Commission has finally taken this crucial step toward rulemaking. We remain concerned, however, that if the Commission adopts an approach to rulemaking that relies on faulty assumptions, it could let this opportunity slip away without providing meaningful and much needed new protections to vulnerable investors. We therefore appreciate that the Commission has requested not just data to support an economic analysis of these issues, but also comment on the assumptions that are presented in the release and the alternative regulatory approaches that the Commission should consider in deciding how best to proceed. Our comments will focus primarily, but not exclusively, on these issues.