The National Association for Fixed Annuities (“NAFA”) is strongly urging that the Department of Labor’s (“DOL’s”) proposed rule changing the definition of “fiduciary” under ERISA be withdrawn.If the DOL insists on revising the longstanding rule that benefits consumers and employees, NAFA’s position is that DOL should re-propose the rule after addressing the wide-ranging and valid concerns interested parties have raised and, subsequently, allow the parties to review and comment on any new proposal. NAFA’s position is consistent with that of other financial services industry trade groups, as well as that of a large bipartisan group of Senate and House members. This DOL proposal is highly controversial and would be extremely disruptive and harmful to the millions of Americans who rely on employer-sponsored plans and IRAs to meet their retirement goals and to our nation’s policy of encouraging savings for retirement, as well as to financial professionals who offer retirement products, to the companies that provide these products, and to small businesses who help educate and advise employees on retirement planning. This proposed rule must not be allowed to become effective without fundamental, extensive changes to the current draft.