and like the investment company act, actually, erisa -- which is the statute they're interpreting -- has a kind of shadow exemptions. .. at the same time they put the cart before the horse, created an exception to the prohibited transaction deceptions of prohibitions that completely swallow the rule and creates but no as a seller exception to say because i am a seller i don't owe you a fiduciary duty. indeed a while has a prohibited transaction exemption. i think it's pte 71 that covers exactly the transaction and proposal that it created so is the exemption, greatly expanding the category without real thought as to whether it's appropriate, especially as to retail investors appeared to give an example, it would mean the mom-and-pop goes by municipal security would not be good. that is religious the beginning of the problems that a short op-ed can deal with. there are problems in the drafting of the rule. there's a fundamental problem of the department's consideration extended to individual retirement accounts, which are fundamentally not a significant problem that is really caught m