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Another Proposed Delay for the DOL Fiduciary Rule

On Aug. 31, 2017, the Department of Labor (DOL) announced a proposed 18-month extension from Jan. 1, 2018, to July 1, 2019, for the Fiduciary Rule’s Best Interest Contract (BIC) Exemption and the Principal Transactions Exemption, and certain amendments to Prohibited Transaction Exemption 84-24.  Under transition period guidance which delayed implementation of these rules until Jan. 1, 2018, a fiduciary adviser must only comply with the Impartial Conduct Standards of the rules through Dec. 31, 2017. 

Under the proposed extension, this transition period would be extended until July 1, 2019.  In addition, under Field Assistance Bulletin 2017-03, the DOL announced a nonenforcement policy regarding the requirement that these exemptions are not available if a client is required to waive his or her right to participate in a class action and must instead agree to arbitration.

The DOL provides additional information and links to the guidance in its news release issued on Aug. 31, 2017.

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About this Author

Sarah Sise practices exclusively in the heavily regulated and constantly evolving field of employee benefits and executive compensation.
Partner

Sarah Sise practices exclusively in the heavily regulated and constantly evolving field of employee benefits and executive compensation. She advises a wide range of clients, including closely-held companies, tax-exempt organizations and public companies.

Sarah brings over 17 years of experience to the firm and partners with clients to establish, design and implement qualified retirement plans, non-qualified arrangements, welfare and fringe benefit plans, and executive compensation programs. She also guides clients through plan audits and service provider changes.

 

314.342.8062
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