The Dodd-Frank Act clearly emphasized the need to clarify the ongoing confusion, especially in the eyes of the retail investing public, of the distinctions between broker-dealers and investment advisers. It also authorized SEC rulemaking to establish a fiduciary duty standard for broker-dealers. To add to this mix, yesterday FINRA issued a concept proposal on what disclosure broker-dealers should have to provide to their retail customers “prior to commencing a business relationship.” Investment advisers have long had this kind of obligation on a Form ADV. I wouldn’t be surpised if, at the end of this exercise, there is such a thing as a Form BDV.