More than 3,500 days have passed since the US Department of Labor (DOL) upended the financial services industries with its first, self-initiated proposal to redefine “investment advice fiduciary” for purposes of the Employee Retirement Income Security Act of 1974, as amended (ERISA). That initiative, together with the Dodd-Frank Act mandate that the Securities and Exchange Commission (SEC) reconsider the standard of conduct to which broker-dealers should be subject, accelerated more than a decade of reevaluation of and, as a business planning and compliance matter, uncertainty about the duties financial services providers owe to investors, specifically including retirement investors.