tt INVESTACORP

VIA ELECTRONIC MAIL (e-ORI@dol.gov)

To: Office of Regulations and Interpretations
Employee Benefits Security Administration
Attn: Conflict of Interest Rule
U.S. Department of Labor
200 Constitution Avenue NW
Washington, DC 20210

RE: Proposed Conflict of Interest Rule Proposals-RIN 1210-AB32

Investacorp, Inc. (IC) thanks you for the opportunity to comment on the Department’s proposed
amendments to the definition of a “fiduciary” and Retirement Investment Advice Conflict of Interest
Rule Proposal.

IC is an independent financial services firm, headquartered in Miami, Florida, with approximately 475
independent registered representatives. Approximately half of our registered representatives are dually
registered with our corporate SEC Registered Investment Advisory firm, Investacorp Advisory Services,
Inc., therefore allowing them the flexibility to offer their clients investment opportunities tailored
specific to their individual needs through either the broker dealer or the RIA.

While IC can support a standard of care that will require all investment professionals offering
investment advice to retail clients to adhere to, this proposed standard of care should be very carefully
examined to ensure that it is in the best interests of the investor.

The rule as proposed will create higher costs and make it more difficult for clients to receive
individualized investment advice from a trusted advisor. In order to comply with the disclosure
requirements detailed in the Best Interest Contract Exemption (BICE), IC will have to bear substantial
initial and ongoing costs. These costs are probably to find its way down to the independent advisor and
ultimately passed through to the individual client level, therefore increasing the overall cost to the client
to receive investment advice.

Additionally, by excluding products such as Real Estate Investment Trusts and Business Development
Companies in the definition of an “Asset”, the proposed rule limits the ability to products that may
provide for greater overall portfolio diversification for investors.

Investors may be easily confused due to the separate set of standards being applied to broker dealers
that is vastly different than the fiduciary standard applicable to investment advisors. Customers with
varying account registrations for accounts serviced by the same financial advisor may have a hard time
grasping the differences in the standard of care that is relevant to each account. The Department is
urged to apply a uniform standard of care that will be applicable to all accounts to limit the complexity
and confusion that exists based upon the rule as proposed.

4400 Biscayne Blvd., 11th Floor, Miami, Florida 33137
305-557-3000, www.Investacorp.com


As a member of the Financial Services Institute (FSI), IC fully supports the alternative uniform fiduciary
standard proposed in FSIs comment letter on this matter. We believe that this alternative uniform
fiduciary standard, which will be applicable to all investment professionals and all types of accounts,
makes it easier for investors to receive high-quality, individualized investment advice from a trusted
advisor, and provides retail investors with a clear and easy to understand standard of care.

Again, thank you for the opportunity to express our comments regarding this proposal. If you have any
questions, please feel free to contact me at (305) 557-3000.

STNG

Marcus Arneaud

Executive Vice President/Chief Compliance Officer
Investacorp, Inc.

4400 Biscayne Blvd

Miami, Florida 33137