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Black 

Chamber of Commerce E 

-1 -100 Jen'.fe1 S _:\.\- Sire 331 \'\'ash.:ngton, D C 200 5 

J02-466-6SSS Fa~ 202-466--i91S 

'\ :'\\"'\\·.m ~ona:b c.org info@:llaco:na bcc.otg 

August 19, 2015 

The Honorable Thomas E. Perez 

Secretary 

.United States Department of Labor 

200 Constitution Avenue, NW 

Washington, DC 20210 

Re: Definition of the Term "Fiduciary" (RIN 1210-AB32); Best Interest Contract Exemption (ZRIN 

1210-ZA25), Amendment of PTE 84-24 (RIN 1210-ZA25), Amendment of PTE 77-4 (RIN 1210-ZA25) 

Dear Secretary Perez: 

On behalf of the National Black Chamber of Commerce (NBCC), we are writing to the Department of 

Labor (DOL) to sha re our concerns with the DOL's proposed fiduciary ru le. First and foremost, we 

continue to be very concerned that the DOL has proposed a ru le that will severely restrict African 

Americans' and low- to moderate-income Americans' ability to save for retirement. The new 

regulations also will make it difficult for our members- as small business owners- to sponsor 

retirement savings plans for themselves and for the benefit of their employees. 

The NBCC represents the interests of 100,000 Black-owned businesses, with 140 affiliated chapters 

across the nation, international affiliate chapters and businesses, and individual members. We are 

dedicated to economically empowering and sustaining African American communities through 

entrepreneurship and capitalistic activity within the United States. 

The new DOL regulations will likely result in fewer commission-based services in the marketplace, 

leaving only fee-based and managed account services that are not affordable options for many 

individuals in our communities. According to the Financial Industry Regulatory Authority (FINRA), the 

proposed regulation could affect 98% of IRAs with less than $25,000. 

In addition, the small business owner wi ll be hit the hardest under the new regulations, a key 

concern for our members. Small business owners- with fewer than 100 employees-likely will see 

new hurdles for starting up, maintaining, or improving retirement plans for their employees. Our 

members rely on financial advisors as an affordable, reliable source of information on retirement 

saving plans and product offerings and opportunities-a relationship that should not be 

unnecessarily restricted. 

In 2011, NBCC signed a similar letter outlining the negative outcomes of the previously proposed 

ru le, including significantly fewer retirement accounts and less retirement savings. We are 
disappointed that the DOL did not take our concerns into account with this new proposal. We urge 

the DOL to evaluate the economic impact of this proposal on small businesses and re-propose this 

harmful regulation. 

Sincerely, ~ 

~:a-c. ~~ord President/CEO 

cc: Members of Congress 

Sign on Chapters: 

African American Chamber of Commerce of Western Pennsylvania 

African American Chamber of Commerce of New Jersey 

African American Chamber of Commerce of South Carolina 

Alabama State Black Chamber of Commerce 

Arkansas Black Chamber of Commerce 

Augusta Georgia Black Chamber of Commerce 

Bethel's Place Black Chamber of Commerce 

Black Chamber of Commerce of Lake County, Illinois 

Black Chamber of Commerce of Western New York 

Brunswick Regional Black Chamber of Commerce 

Capital District Black Chamber of Commerce, Albany, NY 

Champaign Black Chamber of Commerce 

Chicagoland Black Chamber of Commerce 

Coastal Georgia Minority Chamber of Commerce 

Colorado Springs Black Chamber of Commerce 

Connecticut Black Chamber of Commerce 

Corpus Christi Black Chamber of Commerce 

Cosmopolitan Chamber of Commerce 

Country Club Hills Chamber of Commerce, IL 

Decatur Black Chamber of Commerce 

East New York Black Chamber of Commerce 

East St. Louis Black Chamber of Commerce 

Florence South Carolina Black Chamber of Commerce 

Ft. Wayne Black Chamber of Commerce 

Galesburg Black Chamber of Commerce, II 

Greater Birmingham Black Chamber of Commerce 

Greater Nashville Black Chamber of Commerce 

Greater Southwest Louisiana Black Chamber of Commerce 

Greensboro Black Chamber of Commerce 

Greenwood Chamber of Commerce 

Gulf Coast Regional Black Chamber of Commerce 

Hobbs New Mexico Black Chamber of Commerce 
Illinois Black Chamber of Commerce 

Iowa State Black Chamber of Commerce 

Jacksonville Black Chamber of Commerce 

Joliet Black Chamber of Commerce 

Kansas Black Chamber of Commerce 

lake Charles Black Chamber of Commerce 

Louisiana State Black Chamber of Commerce 

Louisville Black Chamber of Commerce 

Manatee County Black Chamber of Commerce 

Mass Urban Chamber of Commerce, Boston 

Miami Dade Minority Chamber of Commerce 

Minnesota Black Chamber of Commerce 

Mississippi Black Chamber of Commerce 

Missouri State Chamber of Commerce 

Muskegon Black Chamber of Commerce 

Nebraska Black Chamber of Commerce 

New Haven County Black Chamber of Commerce 

New York City Black Chamber of Commerce 

New York State Chamber of Commerce 

Nigeria USA Black Chamber of Commerce 

Northeast Louisiana African American Chamber of Commerce 

Northeast North Carolina Black Chamber of Commerce 

Northern Indiana Black Chamber of Commerce 

Northern Virginia Black Chamber of Commerce 

Northwest Alabama Black Chamber of Commerce 

Oregon Black Chamber of Commerce 

Peoria Black Chamber of Commerce 

Quad City Black Chamber of Commerce 

Quincy Black Chamber of Commerce 

Richmond County Black Chamber of Commerce (NY) 

San Francisco African American Chamber of Commerce 

Shreveport/Bossier City Black Chamber of Commerce 

South Alabama Black Chamber of Commerce 

Tampa Bay Black Chamber of Commerce 

Tennessee Multi Cultural Chamber of Commerce 

The Greater Far South Halsted Chamber of Commerce 

The Gulf Coast African American Chamber of Commerce 

The Ohio State Black Chamber of Commerce 

Toledo African American Chamber of Commerce 

Topeka Black Chamber of Commerce 

Tuscaloosa Black Chamber of Commerce 

Tuskegee Chamber of Commerce 

Utah African American Chamber of Commerce 

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