Complying with Impartial Conduct Standards under the DOL s Fiduciary Rule
|
|
- Clifton Shelton
- 5 years ago
- Views:
Transcription
1
2 Complying with Impartial Conduct Standards under the DOL s Fiduciary Rule JUNE 13, 2017 Blaine Aikin, AIFA, CFA, CFP Duane Thompson, AIFA Executive Chairman, Fi360 Senior Policy Analyst, Fi360
3 Agenda 1. Fiduciary Rule Status Update on DOL, SEC Reviews 2. DOL Temporary Enforcement Policy 3. Compliance with the Impartial Conduct Standards 4. Pending Compliance Requirements on Jan. 1, Q&A 3
4 Why the DOL kept June 9 deadline Feb. 3 Presidential Memorandum seeks new review of Fiduciary Rule We have carefully considered the record in this case, and the requirements of the [APA], and have found no principled legal basis to change the June 9 [compliance] date while we seek public input. Mar. 3 DOL Proposes 60-day delay of April 10 deadline until June 9 under expedited rulemaking - LABOR SECRETARY ALEXANDER ACOSTA, MAY 23, 2017 Late April to May Rule s opponents pressure Acosta to further delay June 9 deadline 4
5 DOL s Next Steps Request For Information (RFI) to be published relatively soon DOL soliciting public comments on various aspects of the Rule including additional delay past Jan. 1 deadline Invites SEC to be a full participant 5
6 SEC Vows Action, Coordination with DOL June 1 Citing need to coordinate with DOL, SEC Chairman Jay Clayton requests public comment on current regulatory framework and range of potential regulatory options 17 Topics include: Investor confusion Conflicts of interest Costs/benefits of different standards (DOL vs. SEC, RIA vs. BD) Disclosure-based approach vs. standards-of-conduct approach 6
7 Roadblocks to Regulatory Harmonization 7
8 DOL Temporary Enforcement Policy The Department has repeatedly said that its general approach to implementation will be marked by an emphasis on assisting (rather than citing violations and imposing penalties on) plans, plan fiduciaries, financial institutions, and others who are working diligently and in good faith to understand and come into compliance with the fiduciary duty rule and exemptions. -- Field Assistance Bulletin (May 22, 2017) 8
9 Temporary Enforcement Policy -- Conditions Effective June 9, 2017 to January 1, 2018 DOL will not pursue claims against fiduciaries working diligently and in good faith to comply with rule and exemptions DOL will consider additional steps to the extent that circumstances surrounding the (Jan. 1 compliance date) and exemptions give rise to the need for other temporary relief DOL policy does not apply to investor disputes brought to arbitration or court Don t forget 408(b)(2) disclosure of fiduciary status if you were not a fiduciary prior to June 9. 9
10 Compliance with the Impartial Conduct Standards [T]his approach provides retirement investors with the protection of basic fiduciary norms and standards of fair dealing, while at the same time honoring the President s directive to take a hard look at any potential undue burdens. -- DOL Rule Preamble (published 4/7/17) extending Apr. 10 deadline 60 days 10
11 A picture worth a thousand pages 11
12 Who is a fiduciary under the Rule? 12
13 Impartial conduct standards - the key to compliance 13
14 Requirements of the best interest standard 14
15 Practices to conform to the best interest standard 15
16 January 1 Compliance Deadline Absent further action by Congress or DOL, as of January 1, 2018: Light enforcement touch by DOL ends Full compliance with eight PTEs goes into effect, for some exemptions this means: Notification to DOL Written acknowledgement of fiduciary status Contract warranties of compliance with ICS Prohibition on quotas, bonuses, contests conflicting with investor s best interest Various disclosures of conflicts, including fees, limitations on products offered Firm contact for complaints Updated website disclosures, including links to BrokerCheck, IARD Recordkeeping for six years 16
17 How the Rule works: rollover advice 17
18 Advice on distributions from retirement plans 18
19 IRA rollover decisions after January 1 19
20 What if the final rule is delayed further or modified? What should you do? Focus only on Impartial Conduct Standards? Don t worry about pending requirements for January 1? Hope for a new streamlined exemption from DOL? Wait until the last minute to hire a compliance expert? 20
21 The professional advisor s mandate Do what is right for the client Duty of Loyalty Deliver professional-grade products and services Duty of Care Run a sustainable business without compromising fiduciary principles In short, do what is right, skillfully and profitably 21
22 Final thoughts DOL s Fiduciary Rule is likely to prevail, albeit with some changes; fundamental fiduciary duties of loyalty and care will remain intact The SEC will not be able to dilute the ERISA fiduciary standard for retirement advice; SEC proposes to introduce a fiduciary standard governing retail advice that is somehow aligned Product/price compression will continue due to greater transparency, regulatory and competitive pressures, and technology-enhanced due diligence Compensation for advice is likely to be stable and ultimately rise as a matter of supply and demand and due to higher standards of conduct Professional practice business models will be most sustainable at the high-end Financial planning and professional specialization will be favored 22
23 Questions, Answers and Discussion Additional information on fiduciary trends can be found at fi360 Fiduciary Talk Podcast (also available on itunes) and the Fi360 Blog 23
The Fiduciary Year In Review (with an eye towards what lies ahead)
The Fiduciary Year In Review (with an eye towards what lies ahead) Presenters: Blaine F. Aikin, AIFA, CFA, CFP Chief Executive Officer Duane R. Thompson, AIFA Senior Policy Analyst 2015 fi360 Inc. All
More informationIn With the New, Out With the Old: A Flood of Quasi Fiduciary Rules Coming fi360 Inc. All Rights Reserved.
In With the New, Out With the Old: A Flood of Quasi Fiduciary Rules Coming Blaine Aikin, AIFA, CFP, CFA Fi360 & CEFEX, Executive Chairman Duane Thompson, AIFA Fi360, Senior Policy Analyst Fiduciary Standard
More informationIN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT. Plaintiffs-Appellants, Defendants-Appellees.
Case: 17-10238 Document: 00514003289 Page: 1 Date Filed: 05/23/2017 IN THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT CHAMBER OF COMMERCE OF THE UNITED STATES OF AMERICA, et al., Plaintiffs-Appellants,
More informationA guide to the fiduciary role in a retirement plan
Retirement Plan Solutions Content provided by: Compliments of TD Ameritrade Institutional A guide to the fiduciary role in a retirement plan Understanding your status, supporting plan sponsors as fiduciaries,
More informationDOL Fiduciary Rule: Impact and Action Steps
Legal Update July 11, 2017 DOL Fiduciary Rule: Impact and Action Steps With the survival of the US Department of Labor s (DOL) new fiduciary rule (at least for now) and the applicability date (June 9,
More information18-Month Extension of Transition Period and Delay of Applicability Dates; Best Interest
This document is scheduled to be published in the Federal Register on 11/29/2017 and available online at https://federalregister.gov/d/2017-25760, and on FDsys.gov DEPARTMENT OF LABOR Employee Benefits
More informationMaking Sense of the Final DOL Fiduciary Rule
Making Sense of the Final DOL Fiduciary Rule An easy guide that compares the proposed rule to the final rule. CHART ILLUSTRATING CHANGES FROM DEPARTMENT OF LABOR S 2015 CONFLICT OF INTEREST PROPOSAL TO
More informationInaugural Memphis Compliance Roundtable
Inaugural Memphis Compliance Roundtable The DOL's Proposed Change to the Definition of Fiduciary Investment Advice Mark Griffin mgriffin@bakerdonelson.com Points: Investment Advice and Fiduciary Status
More informationResources for Responding to the DOL Rule Micah Hauptman Consumer Federation of America
Resources for Responding to the Micah Hauptman Consumer Federation of America 1 Resources for Responding to the Brief Background on Fiduciary Rule Finalized April 2016 Updated definition of fiduciary investment
More informationThe Shifting Landscape of DOL Fiduciary Rule Implementation
The Shifting Landscape of DOL Fiduciary Rule Implementation Mutual Fund Directors Forum Webinar 2017 Dechert LLP Speakers Jay Haines Senior Vice President and Deputy General Counsel Fidelity Investments
More informationInvestment Management Institute 2017
CORPORATE LAW AND PRACTICE Course Handbook Series Number B-2309 Investment Management Institute 2017 Volume One Co-Chairs Barry P. Barbash Paul F. Roye To order this book, call (800) 260-4PLI or fax us
More informationFee Disclosure. Get the 411 on 408(b)(2) Presented by: Ben Healy, AVP, Operations Eric Grzejka, Manager, Retirement Plan Consulting
Fee Disclosure Get the 411 on 408(b)(2) Presented by: Ben Healy, AVP, Operations Eric Grzejka, Manager, Retirement Plan Consulting Save the Date UPCOMING EVENTS May 28 2015 For Companies (New York, NY)
More informationCONFLICT OF INTEREST FAQS (PART I- EXEMPTIONS)
CONFLICT OF INTEREST FAQS (PART I- EXEMPTIONS) U.S. Department of Labor Employee Benefits Security Administration October 27, 2016 New Exemptions and Amendments to Existing Exemptions Under the Employee
More informationDoL FIDUCIARY RULE ~ In Plain English
MBA Risk Management & Compliance Institute September 13, 2017 Shane B. Hansen, Partner Warner Norcross & Judd LLP shansen@wnj.com 616.752.2145 DoL FIDUCIARY RULE ~ In Plain English 2017 Warner Norcross
More informationAn Introduction to Stable Value Funds
An Introduction to Stable Value Funds August 21, 2018 Matthew Gnabasik Managing Partner, Senior ERISA Consultant Blue Prairie Group, LLC John Faustino, AIFA, PPC Chief Product and Strategy Officer Fi360,
More informationBest Practices for Retail Non- Deposit Investment Programs
Best Practices for Retail Non- Deposit Investment Programs Louis Dempsey, Renaissance Ben Marzouk, Eversheds Sutherland David Porteous, Faegre Baker Daniels Agenda Regulatory Developments Focus on Fixed
More informationPreliminary Annotated Responses: Round One Conflict of Interest Exemptions FAQs (10/27/16) 1
Preliminary Annotated Responses: Round One Conflict of Interest Exemptions FAQs (10/27/16) 1 Compliance Dates Q1. When do firms and their advisers have to comply with the conditions of the new BIC Exemption
More informationFor Level Fee Advisors under the New Department of Labor Fiduciary Rule
ROLLOVER GUIDE For Level Fee Advisors under the New Department of Labor Fiduciary Rule When the U.S. Department of Labor s (DOL) new fiduciary rule becomes applicable on June 9, 2017, Loring Ward and the
More informationERISA Regulatory and Litigation Update and Current Fiduciary Issues. FIRMA 29 th National Risk Management Training Conference
ERISA Regulatory and Litigation Update and Current Issues FIRMA 29 th National Risk Management Training Conference Jennifer Eller Groom Law Group, Chartered April 23, 2015 Agenda DOL Regulatory Update
More informationApril 8, Fiduciary Rule Prohibited Transaction Exemption 84-24
April 8, 2016 Fiduciary Rule Prohibited Transaction Exemption 84-24 On April 6, 2016, the U.S. Department of Labor ( DOL ) made available its much-anticipated final regulation on the definition of fiduciary
More informationThe Seven Core Principles Every Fiduciary Should Know and Follow
The Seven Core Principles Every Fiduciary Should Know and Follow J. Richard Lynch, AIFA President, fi360 Mission: fi360 will help our clients gather, grow, and protect assets through better investment
More informationThe DOL + Tibble = You re a Fiduciary; Now What?
The DOL + Tibble = You re a Fiduciary; Now What? Fred Reish, Partner, DrinkerBiddle Dr. Greg Kasten, CEO, Unified Trust Blaine Aikin, Executive Chairman, fi360 Tibble v. Edison International The case involves
More informationDOL Conflict of Interest Proposal: What to Expect?
DOL Conflict of Interest Proposal: What to Expect? Brought to you by the Advanced Consulting Group of Nationwide Nationwide, the Nationwide N and Eagle and Nationwide is on your side are service marks
More informationSEC Proposes Standard of Conduct for Broker-Dealers and Interpretation Regarding Standard of Conduct for Investment Advisers
SEC Proposes Standard of Conduct for Broker-Dealers and Interpretation Regarding Standard of SEC Approves Package of Proposed Rules and Interpretations Designed to Enhance Protections and Preserve Choice
More informationDefinition of the Term Fiduciary ; Conflict of Interest Rule Retirement. Investment Advice; Best Interest Contract Exemption (Prohibited Transaction
This document is scheduled to be published in the Federal Register on 04/07/2017 and available online at https://federalregister.gov/d/2017-06914, and on FDsys.gov DEPARTMENT OF LABOR Employee Benefits
More informationRE: Uniform standards of conduct for brokerage and advisory service models File No. S ; File Number S Dear Chair Clayton and Mr.
Ronald J. Kruszewski Chairman and Chief Executive Officer (314) 342-2155 ronk@stifel.com August 7, 2018 The Honorable Jay Clayton, Chair Mr. Brent J. Fields, Secretary U.S. Securities and Exchange Commission
More informationProposed Regulation - Definition of the Term Fiduciary, 82 Fed Reg (March 2, 2017). 2
March 15, 2017 Mr. Joe Canary, Director Office of Regulations and Interpretations Employee Benefits Security Administration Attn: Fiduciary Rule Examination Room N-5655 U.S. Department of Labor 200 Constitution
More informationIn light of the various twists and
FEATURE Best Practices Arising from the DOL Fiduciary Rule By Marcia S. Wagner, Esq., Barry L. Salkin, Esq., and Livia Q. Aber, Esq. In light of the various twists and turns that have taken place in, it
More informationRETIREMENT READINESS IN THE NEW YEAR
Founded in 1992 Administration of Over 22,000 Plans and 1.2 Million Plan Participants Over $64 Billion in Assets Under Management Plans in All 50 States PG 1 Retirement 2 Are 3 Reasonable 3 ABG 5 Did 6
More informationFederal Register / Vol. 82, No. 228 / Wednesday, November 29, 2017 / Rules and Regulations
Federal Register / Vol. 82, No. 228 / Wednesday, November 29, 2017 / Rules and Regulations 56545 remove MPO(s) with and add in its place MPO wherever it occurs. 13. Amend 450.326 as follows: a. Revise
More informationAugust 7, Assistant Secretary Rutledge:
August 7, 2018 The Hon. Preston Rutledge Assistant Secretary for Employee Benefits U.S. 200 Constitution Ave, NW, Ste S-2524 Washington DC 20210 Re: Requested Clarification to Field Assistance Bulletin
More informationWith quickly approaching deadlines for compliance, Everything You Wanted to Know About BICE but Were Afraid to Ask. Public Policy
Public Policy Everything You Wanted to Know About BICE but Were Afraid to Ask The best-interest contract exemption (BICE) formally known as Prohibited Transaction Exemption (PTE) 2016-01 is part of a large
More informationRetirement Plan Fiduciary Best Practices Houston Compensation and Benefits Total Rewards Summit
Retirement Plan Fiduciary Best Practices Houston Compensation and Benefits Total Rewards Summit Edward A. Razim, Partner September 13, 2018 Fiduciary Status Who is a fiduciary? Any individual or entity
More informationSEC Fiduciary Rule Initiative
SEC Fiduciary Rule Initiative HISTORICAL DISTINCTION BETWEEN ADVISERS AND BROKER-DEALERS In the aftermath of the Great Depression, the U.S. securities industry was reorganized and regulated based on a
More informationDOL Fiduciary Rule. Midland IRA Podcast August 22, 2017
DOL Fiduciary Rule Midland IRA Podcast August 22, 2017 Welcome and thank you for tuning into alternative investment talks with Midland IRA where we talk everything alternative investments. I m Matt Almaguer
More informationDepartment of Labor (DOL) Fiduciary Rule
Department of Labor (DOL) Fiduciary Rule Updated for June 9, 2017 1. What is the DOL Fiduciary Rule? The DOL Fiduciary Rule is a regulation issued by the federal government. The regulation is intended
More informationTo Be or Not to Be... A Fiduciary: Navigating the Fiduciary Regulation
To Be or Not to Be... A Fiduciary: Navigating the Fiduciary Regulation FRED REISH, ESQ. October 24, 2016 Structure of Fiduciary Package Expansion of definition of fiduciary investment advice: covers most
More informationRegulation on service provider fee disclosures for ERISA retirement plans
Regulation on service provider fee disclosures for ERISA retirement plans 2 About MetLife Resources MetLife Resources is the Division of Metropolitan Life Insurance Company that specializes in providing
More informationOutsourcing Fiduciary Responsibility
Outsourcing Fiduciary Responsibility Robert M. Kaplan, APA, CFP, CPC, QPA, Vice President, National Training Consultant, Voya Financial Services Christopher Swanson, J.D., Supervisory Investigator, U.S.
More informationTHE WHITE HOUSE Office of the Press Secretary EMBARGOED UNTIL 6AM ET, WEDNESDAY, APRIL 6, 2016
THE WHITE HOUSE Office of the Press Secretary EMBARGOED UNTIL 6AM ET, WEDNESDAY, APRIL 6, 2016 FACT SHEET: Middle Class Economics: Strengthening Retirement Security by Cracking Down on Conflicts of Interest
More informationDOL finalizes re-definition of ERISA investment advice fiduciary
news and features home DOL finalizes re-definition of ERISA investment advice fiduciary April 11, 2016 On April 6, 2016, the Department of Labor finalized its regulation re-defining who is an investment
More informationRegulatory Compliance: Targeting Solutions for Your Client s Greatest Challenges
fi 360 Annual Conference April 2013 Regulatory Compliance: Targeting Solutions for Your Client s Greatest Challenges Jason C. Roberts, Esq., AIFA Chief Executive Officer Pension Resource Institute, LLC
More informationWho is the Plan Fiduciary? Employment Law Briefing June 25, 2018 CUPA HR Conference 2
Who is the Plan Fiduciary? June 25, 2018 Jacksonville Presented by: Robert S. Ellerbrock Paul Owen (CAPTRUST Advisors) Employment Law Briefing June 25, 2018 CUPA HR Conference 1 Who is a Fiduciary? Basically,
More informationThe Case for Rethinking TDFs as QDIAs
The Case for Rethinking TDFs as QDIAs Presenters: Jake Adamczyk, Associate Vice President of Aurum Advisory Services and Mike McKeown, Director of Research at Aurum Advisory Services 6685 Beta Drive, Mayfield
More informationRetirement Plan Fundamentals Zero to Sixty. Todd Kading, CFP, ChFC, RF LeafHouse Financial Advisors
Retirement Plan Fundamentals Zero to Sixty Todd Kading, CFP, ChFC, RF LeafHouse Financial Advisors Meet Our Speaker Todd Kading Managing Director LeafHouse Financial Advisors Top 10 Most Dependable Wealth
More informationBank of America Merrill Lynch Legislative and Regulatory Brief
RETIREMENT & BENEFIT PLAN SERVICES Bank of America Merrill Lynch Legislative and Regulatory Brief July 2014 www.baml.com/publicpolicyinsights DOL Regulatory Project Plan Revised Status On May 27, 2014,
More informationFinal Regulation on Service Provider Fee Disclosures for ERISA Retirement Plans
Final Regulation on Service Provider Fee Disclosures for ERISA Retirement Plans About MetLife For over 140 years, MetLife has been one of the country s most trusted financial institutions. The MetLife
More informationtwo thousand eight ISSUE BROCHURE 403(b) Plans Frequently Asked Questions
Brochure 2-403bFAQs 11x17 - FINAL:Fact Sheet 2008.qxd 10/29/2008 11:04 AM Page 1 National Association of Government Defined Contribution Administrators, Inc. two thousand eight ISSUE BROCHURE 403(b) Plans
More informationDepartment of Labor Fiduciary Rule
Department of Labor Fiduciary Rule Hillel Cohn March 8, 2017 MORRISON & FOERSTER LLP 2017 mofo.com Status of the DOL Fiduciary Rule Adopted by the DOL in April 2016 Became effective in June 2016, with
More informationCREATING A CULTURE OF FIDUCIARY RESPONSIBILITY
CREATING A CULTURE OF FIDUCIARY RESPONSIBILITY Presented by: Mark Hogan Regional Director Pentegra Retirement Services July 2016 Our Difference. Your Advantage. IN THE NEWS How Lawsuits Are Reshaping 401(k)
More informationThe U.S. Department of Labor s New Conflict of Interest Regulation Implications for Non-U.S. Investment Managers
Copyright 2016 by K&L Gates LLP. All rights reserved. The U.S. Department of Labor s New Conflict of Interest Regulation Implications for Non-U.S. Investment Managers Robert Sichel, Partner, K&L Gates
More informationUsing Unitized Managed Accounts in 401(k) Plans
Content provided by Using Unitized Managed Accounts in 401(k) Plans by Fred Reish and Bruce Ashton Compliments of Why is TD Ameritrade Institutional making this information available to you? At TD Ameritrade
More informationNew ERISA 408(b)(2) Regulations Mastering Detailed Requirements for Service Provider Fee Disclosures
Presenting a live 110 minute webinar with interactive Q&A New ERISA 408(b)(2) Regulations Mastering Detailed Requirements for Service Provider Fee Disclosures WEDNESDAY, JANUARY 26, 2011 1pm Eastern 12pm
More informationOn April 8, 2016, the Department of Labor
The Investment Lawyer Covering Legal and Regulatory Issues of Asset Management VOL. 25, NO. 10 OCTOBER 2018 Broker-Dealers as Fiduciaries After the DOL Rule Vacatur By David C. Kaleda On April 8, 2016,
More informationInvestment Advisers as Fiduciaries
The DOL s New Rules for Retirement Investment Advice Douglas J. Heffernan, Megan E. Hladilek, and Graham P. Widmer Faegre Baker Daniels LLP After years of debate and speculation, the Department of Labor
More informationThe DOL s Fiduciary Rule: Where It s Going
SM PlanAdvisorTools.com The DOL s Fiduciary Rule: Where It s Going By Fred Reish - Partner, Drinker Biddle & Reath LLP SM The DOL s Fiduciary Rule: Where It s Going by Fred Reish Partner, Drinker Biddle
More informationRE: Request for Information Regarding the Fiduciary Rule and Prohibited Transaction Exemption (RIN 1210-AB82)
August 7, 2017 Submitted Electronically Office of Exemption Determinations Employee Benefits Security Administration (EBSA) Attention: D-11933 U.S. Department of Labor 200 Constitution Avenue NW Suite
More informationMultiple Employer Plans: An Institutional-level Fiduciary and Administrative Solution for the Smaller End of the 401k Market
Multiple Employer Plans: An Institutional-level Fiduciary and Administrative Solution for the Smaller End of the 401k Market Multiple Employer Plans Breakout Session Participants Terrance Power, CFP, AIFA,
More informationLegislative & Regulatory Update
Legislative & Regulatory Update ABA Trust & Wealth Management Conference Thursday, November 3, 2016 Cristeena Naser American Bankers Association Legislative Developments Evolving Fiduciary Boundaries SEC
More informationThe Fiduciary Landscape Today. Today. 1. Who Is A Fiduciary. 2. Industry Models. 3. As The Trusted Business Advisor 6/14/2017
The Fiduciary Landscape Today William C. Clifford, Esq. Beacon Benefits June 21,2017 Today 1. Who Is A Fiduciary 2. Industry Models 3. As The Trusted Business Advisor 1 1. Who Is A Fiduciary Named Fiduciaries
More informationStep 2 of the Fiduciary Process: Organizing the Client Engagement
Step 2 of the Fiduciary Process: Organizing the Client Engagement Michael Muirhead, AIF, PPC Fi360, Senior Vice President, Learning and Development Topics Recognize what it means to be a fiduciary Identify
More informationBenefits. DOL Fee Disclosure Regulations: What Plan Sponsors Need to Know
Benefits cus Employer Update DOL Fee Disclosure Regulations: What Plan Sponsors Need to Know October 2011 Retirement plan fees and their impact on the retirement savings of plan participants is a topic
More informationWhat the new DOL definition of an investment advice fiduciary means for retirement plan advisers
DOL Fiduciary Rule White paper What the new DOL definition of an investment advice fiduciary means for retirement plan advisers Christine Cushman, JD, LLM, CLU Summary I. The new definition of investment
More informationA prudent process the key to demonstrating fiduciary compliance
DOL Practice Management White paper NATIONWIDE RETIREMENT INSTITUTE The Nationwide Retirement Institute provides practical thought leadership through timely insights and education, client-ready tools and
More informationThe DOL Fiduciary Rule. Questions & answers by Fred Reish. Retirement Plan Solutions. Content provided by. Compliments of
Retirement Plan Solutions Content provided by The DOL Fiduciary Rule by Fred Reish Compliments of The law and analysis contained in these questions and answers are current as of June 2016, are general
More informationThe Department of Labor Fee Transparency Initiatives: Part 2 - Mandatory Service Provider Fee Disclosures - Updated
Volume 2012 May 1 The Department of Labor Fee Transparency Initiatives: Part 2 - Mandatory Service Provider Fee Disclosures - Updated For a number of years, the Department of Labor has been concerned about
More information2016 INVESTMENT MANAGEMENT CONFERENCE. ERISA Developments. Robert L. Sichel, Partner, New York. Copyright 2016 by K&L Gates LLP. All rights reserved.
2016 INVESTMENT MANAGEMENT CONFERENCE ERISA Developments Robert L. Sichel, Partner, New York Copyright 2016 by K&L Gates LLP. All rights reserved. TOPICS Changing Retirement Landscape New DOL fiduciary
More informationThe Outlook for the Fiduciary Standard in Washington Bullish, Bearish? A Report on the Status of Fiduciary Status
The Outlook for the Fiduciary Standard in Washington Bullish, Bearish? A Report on the Status of Fiduciary Status 2011 fi360 Annual Conference San Antonio, Texas May 5, 2011 Knut A. Rostad, Chairman The
More informationMay 1, Washington, D.C Washington, D.C
May 1, 2017 The Honorable Jeb Hensarling The Honorable Maxine Waters Chairman Ranking Member Committee on Financial Services Committee on Financial Services U.S. House of Representatives U.S. House of
More informationDOL Fiduciary: When They're Running You Out of Town - Get at the Head of the Line and Make it Look Like a Parade!
Kim O Brien MBA, CEO and Chief Advocate Richard M. Weber, MBA, CLU, AEP (Distinguished) President DOL Fiduciary: When They're Running You Out of Town - Get at the Head of the Line and Make it Look Like
More informationGetting it right. Know Your Fiduciary Responsibilities. The Employee Benefits Security Administration U.S. Department of Labor
The Employee Benefits Security Administration U.S. Department of Labor Getting it right Know Your Fiduciary Responsibilities A Compliance Assistance Program 1 Fiduciary Responsibility - Overview What is
More informationA NEW FIDUCIARY RULE FOR THE INVESTMENT ADVICE PLAYBOOK
PlanAdvisorTools.com A NEW FIDUCIARY RULE FOR THE INVESTMENT ADVICE PLAYBOOK How the DOL s Fiduciary Rule Has Fundamentally Changed Investment Advice for IRAs By Fred Reish - Partner, Drinker Biddle &
More informationTHE BENEFITS OF CHOOSING AN A MATTER OF TRUST: Accredited Investment Fiduciary Analyst DESIGNEE
THE BENEFITS OF CHOOSING AN A MATTER OF TRUST: Accredited Investment Fiduciary Analyst DESIGNEE Are You Effectively Acting in Your Beneficiaries Best Interests? FULLY UNDERSTAND YOUR FIDUCIARY RESPONSIBILITIES
More informationFiduciary Responsibility, Delegation & Oversight Multnomah Group, Inc. All Rights Reserved.
2003 2015 Multnomah Group, Inc. All Rights Reserved. About the Presenter Amy Barber is the Chief Compliance Officer and Director of Technical Services for Multnomah Group. She is responsible for the development,
More informationDOL FIDUCIARY STANDARD:
DOL FIDUCIARY STANDARD: C OUNTDOWN TO THE I MPLEMENTATION OF THE F INAL R ULE Presented By: Lawrence T. Divers CRSP, CISP, CRC, AIFA, CWS, AFIM THE FIDUCIARY STANDARD OF CARE Overview of the DOL Fiduciary
More informationSEC s Standards of Conduct for Investment Professionals Rulemaking Package 1
SEC s Standards of Conduct for Investment Professionals Rulemaking Package 1 On April 18 th, the Securities and Exchange Commission ( SEC or Commission ) voted to propose a package of three rulemakings
More informationThe DOL Issues Long Awaited Final Rule on the Definition of an ERISA Fiduciary
Plan Sponsor Council of America April 19, 2016 The DOL Issues Long Awaited Final Rule on the Definition of an ERISA Fiduciary After a drawn out and controversial regulatory review process, the United States
More informationFebruary 5, The Honorable Jay Clayton Chairman Securities and Exchange Commission 100 F Street, NE Washington, D.C
The Honorable Jay Clayton Chairman Securities and Exchange Commission 100 F Street, NE Washington, D.C. 20549 Re: Public Comments from Retail Investors and Other Interested Parties on Standards of Conduct
More informationThe Impact of the DOL Fiduciary Duty Rule on Bank Broker-Dealer Distribution of Securities and Insurance
Clifford E. Kirsch W. Mark Smith April 25, 2016 The Impact of the DOL Fiduciary Duty Rule on Bank Broker-Dealer Distribution of Securities and Insurance All Rights Reserved. This communication is for general
More informationRe: Release No , Request for Comment, Draft FY Strategic Plan for the Securities and Exchange Commission
Īll MSRB Municipal Securities Rulemaking Board The Honorable Jay Clayton Chairman 100 F Street, NE Washington, D.C. 20549 Re: Release No. 34-83463, Request for Comment, Draft FY 2018-2022 Strategic Plan
More informationBackground and Impact on Retirement Savers
Protecting Retirement Savings FAQs as released by the U.S. Department of Labor in April 2016, except for annotations in red added by NELP in June 2017 NELP Note: On February 3, 2017, President Trump directed
More informationWhat the DOL s New 408b 2 Rule Means
What the DOL s New 408b 2 Rule Means July 16 2010 DOL published its long awaited 408b 2(c) regulation on July 15, 2010. The new interim final regulation makes some thoughtful upgrades to the 2007 proposed
More informationPlan Sponsor Fee Disclosure
Plan Sponsor Fee Disclosure Standard Retirement Services, Inc. Overview Full, clear disclosure of all fees associated with qualified retirement plans has long been a goal of the Department of Labor (DOL).
More informationImpact Analysis How the 2010 Advice Regulation Proposal Affects Adviser Business Activity and Probability of Enactment of Regulation
Impact Analysis How the 2010 Advice Regulation Proposal Affects Adviser Business Activity and Probability of Enactment of Regulation March 4, 2010 DALBAR Due Diligence & Audit Services Table of Contents
More informationTHE DOL FIDUCIARY REDEFINITION HOW SHOULD YOUR FIRM PREPARE?
THE DOL FIDUCIARY REDEFINITION HOW SHOULD YOUR FIRM PREPARE? Moderator: David Porteous, Faegre Baker, DanielsD Panelists: Mark Smith, Sutherland, Asbill & Brennan Jeff Walter, Chief Compliance Officer,
More informationRequest for Information Regarding the Fiduciary Rule and Prohibited Transaction Exemptions RIN 1210-AB82
July 18, 2017 Office of Exemption Determinations Employee Benefits Security Administration Attn: D-11933 U.S. Department of Labor 200 Constitution Avenue NW Suite 400 Washington, DC 20210 Re: Request for
More informationpay, but they able to
Universal Coverage: USA Retirement Funds would provide every working person in America with access to a retirement plan throughh an automatic payroll deduction. Employers with more than 10 employees would
More informationDALBAR Due Diligence: Trust, but Verify
THE WORK BEHIND BICE PAPERWORK WHAT YOU WILL ACTUALLY HAVE TO DO Abstract Complying with the Best Interest Contract Exemption ( BICE ) requires a mountain of paperwork that commits, promises, and makes
More informationYOU ARE AN ERISA FIDUCIARY, NOW WHAT?
YOU ARE AN ERISA FIDUCIARY, NOW WHAT? November 18, 2015 Rebecca E. Greene 414-298-8244 rgreene@reinhartlaw.com 1000 North Water Street, Suite 1700, Milwaukee, WI 53202 www.reinhartlaw.com Webinar Housekeeping
More informationHEDGE FUND ADVISER REGISTRATION AND COMPLIANCE
HEDGE FUND ADVISER REGISTRATION AND COMPLIANCE Cary J. Meer Mark D. Perlow September 19, 2005 DC-#728969-v2 Current Exemption from Registration Until February 1, 2006, where advice is provided to an entity
More informationConsiderations for Registered Investment Advisors
The DOL Conflict of Interest Rule Considerations for Registered Investment Advisors The Department of Labor s Conflict of Interest Rule (the Rule) has broad implications for the financial services industry.
More informationRollovers and IRA Transfers: Navigating Treacherous Waters FRED REISH, ESQ.
Rollovers and IRA Transfers: Navigating Treacherous Waters FRED REISH, ESQ. April 26, 2018 The Fiduciary Rule: Where Are We Now? Timeline for the fiduciary rule: June 9, 2017: Fiduciary regulation expanding
More informationFee Disclosure Q&A for Employers September 2014
Fee Disclosure Q&A for Employers September 2014 The Department of Labor (DOL) has issued two sets of final regulations requiring the disclosure of fees and expenses under plans governed by the Employee
More informationDOL fiduciary rule update What it means and how it impacts advisors
DOL fiduciary rule update What it means and how it impacts advisors April 28, 2016 For broker/dealer use only. Not to be used with the public. DoL publishes final fiduciary rule April 6, 2016 Unpacking
More informationindependent financial expert and the fiduciary that would be the product provider or an affiliate of the investment provider.
INVESTMENT ADVICE TO DEFINED CONTRIBUTION PLAN PARTICIPANTS- UPDATE ON IMPACT OF DEPARTMENT OF LABOR ADVISORY OPINION 2001-09A AND THE PENSION PROTECTION ACT OF 2006 Under Section 3 (21) (A) (ii) of ERISA,
More informationBriefing Room. The White House. February 02, 2017
1 of 8 Briefing Room Speeches & Remarks Press Briefings Statements & Releases Presidential Actions Legislation Nominations & Appointments Disclosures The White House February 02, 2017 MEMORANDUM FOR: REGULATORY
More informationThe Fiduciary Re-Proposal: The New Definition and Its Consequences
The Fiduciary Re-Proposal: The New Definition and Its Consequences FRED REISH, ESQ. Fred.Reish@dbr.com www.linkedin.com/in/fredreish April 27, 2012 Fiduciary Status for Investment Advice The Department
More informationWhile most broker-dealers and investment advisers know whether
Vol. 20, No. 2 February 2013 A Matter of Trust: Standards of Conduct under ERISA, the Exchange Act, and the Advisers Act: Part 1 of 2 By David C. Kaleda While most broker-dealers and investment advisers
More informationManaging the Managers: International Coordination of Financial Supervision
Managing the Managers: International Coordination of Financial Supervision Barbara Novick, Vice Chairman May 2017 The opinions expressed are as of May 2017 and may change as subsequent conditions vary.
More informationGAME CHANGER: A FIRST LOOK AT THE DOL S 2015 CONFLICT OF INTEREST PROPOSAL GAME CHANGER A FIRST LOOK AT THE DOL S 2015 CONFLICT OF INTEREST PROPOSAL
GAME CHANGER: A FIRST LOOK AT THE DOL S 2015 CONFLICT OF INTEREST PROPOSAL 2015 GAME CHANGER A FIRST LOOK AT THE DOL S 2015 CONFLICT OF INTEREST PROPOSAL The retirement plan industry has been waiting for
More information