in our vowiew, it should be consistent across the retail market. that was addressed in a question floyd had from the field. it should be consistent with the -- in our view should be consistent with the intent that congress defined in section 913. our concern with the department of labor's proposal is not with its definition of best interest or as i stated we support that and it's largely where we are today. rather, it is the further conditionality and restrictions on investors that the department seeks to impose on top of and beyond that standard that we believe is extraneous, burdensome and ultimately in a practice inconsistent with the best interest of the client. the dol's proposed definition of who is a fiduciary is broad. encompassing many more activities than ever intended or that the department originally proposed in 2010. for example, the seller's exception for the previous version allowed brokers to market activities to retail customers. this time, there is no sellers exemption to retailmarket to a small business owner. while there is an e