Consumer Federation of America expands on an earlier comment letter in support of the proposed conflict of interest rule and best interest contract and principal transaction exemptions. A primary purpose of this second letter is to respond to some of the suggested revisions to the proposed rule that were submitted by industry rule opponents in the first round of comments and that, if adopted, would fatally undermine its core investor protections. These include a variety of proposals to inappropriately narrow the definition of fiduciary investment advice and to weaken the best interest standard, particularly with regard to mitigation of conflicts. In addition, this letter looks more closely at the types of policies and procedures that could be adopted to mitigate conflicts.