On June 5, 2019, the Securities and Exchange Commission (“SEC” or “Commission”) in a divided 3-1 vote, approved a package of rulemakings and interpretations designed to enhance the quality and transparency of investors’ relationships with broker-dealers and investment advisers while preserving access to a variety of types of advice relationships and investment products. Adopted pursuant to a grant of rulemaking authority in Section 913(f) of the Dodd-Frank Act,1 this long overdue package reflects almost two decades of study and engagement and thousands of comment letters. These rules and interpretations are...