ABA believes that banks, in their capacity as fiduciaries, should act in the best interest of their retirement customers, since these individuals rely on and entrust their banks to provide retirement services, including investment products, retirement planning, and investor education, in order to achieve a secure financial retirement. As DOL undertakes to revise the standard for fiduciary investment advice, it should focus on a functional rule that (i) specifically targets bona fide fiduciary conduct, (ii) provides certainty of compliance, and (iii) meets the standards of wise public policy that truly serves financial services customers.
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