On December 18, 2020, the US Department of Labor (DOL or Department) adopted with limited changes its Proposal 3.0 regarding ERISA fiduciary investment advice, focused on the fiduciary status of rollover advice

and a “best interest” prohibited transaction exemption (PTE) for conflicted advice aligned with the primary regulation of various types of financial services providers. It seems entirely doubtful, however, that this guidance will be the final word on these issues.