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Disclosure Requirements Best Interest Contract Exemptions

Carlton Fields

SEC Regulation Best Interest: Charting a Course for Securities and Annuity Sales

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In June, we circulated our fifth article on the continuing saga regarding the standard of conduct for sales of securities and annuities — and the efforts of federal and state regulators to impose new conditions on the...more

Bradley Arant Boult Cummings LLP

The End of the DOL’s Fiduciary Rule - Employee Benefits Alert

On June 21, 2018, the Fifth Circuit Court of Appeals issued a mandate vacating the controversial fiduciary rule issued by the U.S. Department of Labor (DOL) in 2016. The mandate follows the court’s opinion issued on March 15,...more

Carlton Fields

Several Teams Compete To Reach NAIC Suitability Model Finals

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On May 31 and June 1, several teams competed over proposed revisions to the Suitability in Annuity Transactions Model Regulation (#275) (Suitability Model) at the in-person meeting of the National Association of Insurance...more

Womble Bond Dickinson

Recent Developments Toward A Fiduciary Standard For Brokers

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Much has happened since we last reported on the Department of Labor’s Fiduciary Rule. The compliance deadline was extended 18 months to July 1, 2019. A federal appellate court vacated the Fiduciary Rule in its entirety. The...more

Katten Muchin Rosenman LLP

SEC Proposes Fiduciary Rule for Broker-Dealers

On April 18, concurrently with its publication for comment of a proposed set of enhanced investment adviser regulations, the Securities and Exchange Commission (SEC) published a separate proposal related to the conduct...more

Carlton Fields

Expect Focus - Volume I, March 2018

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EXPECTFOCUS® is a quarterly review of developments in the insurance and financial services industry, provided on a complimentary basis to clients and friends of Carlton Fields Jorden Burt, P.A. ...more

Carlton Fields

New York Department of Financial Services Rings in the New Year with New Suitability Requirements for Insurance Companies

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New York’s Department of Financial Services decided to bid farewell to 2017 and ring-in the new year by proposing to amend Suitability in Annuity Transactions, 11 NYCR 224 (the Annuity Suitability Rule). On December 27, 2017,...more

Proskauer - Employee Benefits & Executive...

Department of Labor Finalizes 18-Month Delay of Fiduciary Rule Exemptions

On November 27, 2017, the Department of Labor (“DOL”) finalized the delay of the applicability date for certain conditions for exemptions to the fiduciary rule until July 1, 2019. This delay was initially proposed in late...more

Proskauer - Employee Benefits & Executive...

Department of Labor Officially Proposes Delaying Fiduciary Rule’s Exemptions for 18 Months

On August 30, 2017, the Department of Labor (“DOL”) officially proposed delaying the applicability date of exemptions to its fiduciary rule until July 1, 2019. The proposal was expected after DOL stated in a court filing...more

Stinson - Corporate & Securities Law Blog

New SEC Chair Announces Guiding Principles

In remarks before the Economic Club of New York, new SEC Chairman Jay Clayton discussed eight guiding principles: Principle #1: The SEC’s mission is our touchstone. Investors and capital markets will suffer if the SEC...more

Morrison & Foerster LLP

Living with the DOL Fiduciary Rule: Be Prepared for the June 9 Implementation Date

The first phase of the Department of Labor’s (“DOL”) new fiduciary rule (“Fiduciary Rule”) is scheduled to be implemented on June 9, 2017. The Fiduciary Rule greatly expands the categories of persons who are deemed...more

K&L Gates LLP

Department of Labor Releases the First of Three Sets of FAQs on the Fiduciary Rule and Exemptions

K&L Gates LLP on

The April 10, 2017, compliance date for the United Stated Department of Labor’s (“DOL”) new fiduciary rule (the “Fiduciary Rule”) is approaching quickly; even while the Fiduciary Rule’s fate under the new Trump administration...more

Dechert LLP

The DOL Issues “Investment Advice” FAQs – Continues to Try to Find an Ideal Balance for the Brave New Fiduciary World

Dechert LLP on

The U.S. Department of Labor (the “DOL”) released its first set of FAQs (the “FAQs”) regarding the DOL’s recently finalized “investment advice” regulation and various related exemptions (collectively, the “Final Rules”) on...more

Ballard Spahr LLP

Investment Management Update

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Investment Adviser AXA Wins Excessive Fee Trial - A federal judge in New Jersey has ruled in favor of AXA Equitable Life Insurance Company (AXA Equitable) and its wholly owned subsidiary, AXA Equitable Funds Management...more

Ballard Spahr LLP

Investment Management Update

Ballard Spahr LLP on

The Securities and Exchange Commission Adopts Amendments to Form ADV and Investment Adviser Act Rules - The Securities and Exchange Commission (SEC) adopted amendments to Form ADV and Investment Advisers Act of 1940...more

Dechert LLP

Navigating the DOL’s New Fiduciary Rules: A Game Plan for Broker-Dealers

Dechert LLP on

This OnPoint focuses on the new and amended fiduciary investment advice regulations issued by the U.S. Department of Labor (DOL) and accompanying prohibited transaction exemptions (Final Rules), from the perspective of...more

Mintz - Employment Viewpoints

The Department of Labor’s 2016 Final Fiduciary and Conflict of Interest Regulations: Amendments to Prohibited Transaction...

This post continues our examination of the Department of Labor’s suite of final fiduciary and conflict of interest regulations. Our previous posts discussed the newly expanded definition of “investment advice fiduciary”; the...more

Winstead PC

Might You Be Stumbling Into Being Subject to the U.S. Department of Labor’s Conflict of Interest Regulatory World?

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The U. S. Department of Labor’s Conflict of Interest regulatory package (the “COI Rules”) reaches far more than traditional trustees named in retirement plan documents. Many financial advisors, tax advisors, investment...more

Winstead PC

New PTEs Impact Broker’s and Advisor’s Relationship with Retirement Plans and IRAs and Also Impact Plan Sponsors and Fiduciaries

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While only the plan service providers, like brokers, are required to comply with the requirements of the revised and new prohibited transaction class exemptions contained in the package with the definition of...more

Bryan Cave Leighton Paisner

The DOL Fiduciary Rule and Potential Limitations On Investor Choice

On Wednesday, April 6, 2016, the United States Department of Labor (the “DOL”) released the final version of its rule imposing a “best interest” fiduciary standard on financial professionals who provide retirement savings...more

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