The Division of Economic and Risk Analysis (DERA) has identified early next year as the likely completion date for its economic analysis regarding the regulatory standards that should apply when broker-dealers and investment advisers provide personalized investment advice to retail customers. CFA is encouraged that the Commission appears to be making progress on this important investor protection priority. For far too long Commission policy has allowed broker-dealers to market themselves to the public as trusted advisers without imposing the fiduciary standard appropriate to such a relationship of trust. A thorough, well-reasoned analysis by DERA has the potential to lay the groundwork for a strong, pro-investor policy. On the other hand, a faulty analysis could doom, or at the very least further delay, prospects for reform.