Do you want to tell the Department of Labor you’re against its fiduciary proposal? Some words bear repeating.

In the case of SIFMA, that word is “access.” In the organization’s 264-page letter to the DOL, it uses the word 72 times.

It says the fiduciary rule would deny small investors “access” to advice.

“This change would lead to decreased access to one-on-one financial guidance.”

It “would result in fewer Americans having access to the help and guidance they need.”

It “risks reducing many investors' access.”

A related word, “choice” appears 24 times in the letter.

“If I had a nickel for every time [SIFMA General Counsel] Ira Hammerman used the word ‘choice’ in a debate with me, I’d be rich,” said rule proponent Knut Rostad, president of the Institute for the Fiduciary Standard.

By contrast, if Rostad had a nickel for the number of times SIFMA used the phrase “investor protection” in its comment, he could have bought five pennies.

In Washington, where repetition is often viewed as the lifeblood of persuasion, buzzwords drone on incessantly.

The city is suspected of being the birthplace of buzzword bingo, a game in which cards are prepared with clichés and bored congressional staffers can keep awake during hearings by ticking off several in a row.

One favorite buzzword of the anti-fiduciary rule set is “unworkable.” It was actually in the title of a Senate committee hearing this week opposing the rule. It is repeated 14 times in the SIMFA letter and eight times in the opposition piece from the U.S. Chamber of Commerce.

“Liability” was popular as well: It was used 31 times in the SIFMA letter and eight times by the Chamber of Commerce.

Fiduciary rule proponents have less opportunity, though, because their smaller staffs prepare shorter comment letters.

However, in its 83-page letter, the Consumer Federation of America brought forth “investor protection” 10 times more than SIFMA did.

Which is to say, 10 times versus one.