Former SEC Economists File Comment Letter Criticizing Economic Analysis Underlying Regulation Best Interest Rule Proposal

February 15, 2019

On February 6, 2019, a group of 11 former SEC senior economists filed a comment letter criticizing the economic analysis underlying the SEC’s Regulation Best Interest Rule Proposal, which consists of three related rules aimed at reforming the way registered investment advisers and broker-dealers service retail customers. The letter states that the economic analysis is weak and incomplete and even appears inconsistent with parts of the SEC’s own adopted guidance for fashioning a rule’s economic analysis. The letter, among other things, questions whether the economic analysis for the three rules completely identifies the specific problems needing attention.


Compliance, Exchange-Traded Funds (ETFs), Investment Advisers, Investment Companies, Mutual Funds, Regulatory