“Vanguard strongly believes that investors should always receive investment advice that is in their best interest, and those who provide investment advice should be held to a fiduciary standard,” wrote Vanguard CEO Bill McNabb in the public comment letter. “However, Vanguard urges the Department to modify the scope of its definition of investment advice and certain operational aspects of the Rule to protect investors in an efficient and cost-effective way while promoting access to high-quality investment advice, information and education.”

Vanguard’s comments are grounded in five core principles:

  • The DOL should revise, not revoke, the rule, but no rule should be implemented piecemeal before the presidentially ordered review is complete.
  • The definition of investment advice should be more targeted to protect investors’ access to investment education and advice.
  • Consistent requirements should apply to investment advice regardless of client, delivery method, or topic.
  • Regulatory requirements should be harmonized across agencies to create a consistent investor experience in retirement and non-retirement accounts to the extent feasible, but not at the expense of unduly delaying the rule.
  • Operational requirements should be more efficient and enforcement methods more streamlined for investors.

For more details, you can read the full version of Vanguard’s public comments here. PDF