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Principal Transaction Exemption

ERISA Newsletter - Third Quarter 2017

by Proskauer Rose LLP on

Editor's Overview - As we have observed on other occasions, the ERISA class action plaintiffs' bar has, for several years now, honed in on 401(k) plan fiduciaries and their decisions to select and retain investment options...more

DOL Proposes Rule to Extend Applicability Date of BIC and Other Exemptions

by Tucker Arensberg, P.C. on

The Department of Labor published a Proposed Rule to extend from January 1, 2018 to July 1, 2019, the applicability date of the Best Interest Contract (“BIC”) Exemption, the Class Exemption for Principal Transactions in...more

The Final Rule: DOL Proposes to Extend Transition Period until July 1, 2019, and Issues Additional Non-Enforcement Policy for...

By a notice published in the Federal Register on August 31, 2017, the Department of Labor proposed to extend from January 1, 2018, until July 1, 2019, the date for compliance with the full conditions in its new “investment...more

DOL Issues Proposed Delay of Fiduciary Rule Compliance Date and Enforcement Relief

by Morgan Lewis on

The proposal would extend the transition period to July 1, 2019. The US Department of Labor (DOL) has proposed to delay the applicability of additional conditions of the Best Interest Contract (BIC) exemption, Principal...more

DOL Proposes to Defer Full Implementation of its Fiduciary Rule Until July 1, 2019

In April 2016, the U.S. Department of Labor (DOL) adopted a rule that significantly expands the category of persons deemed fiduciaries when providing investment recommendations to most retail retirement accounts (the...more

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

Possible Further Delay of ERISA Fiduciary Rule

On August 9, 2017, the Department of Labor (DOL) and Secretary of Labor, Alexander Acosta, submitted a proposal to the Office of Management and Budget (OMB) to further delay the applicability date of certain parts of the...more

Does a Proposal for Further Delay in Implementation of the DOL Fiduciary Rule Suggest Major Changes Are Coming?

On August 9, 2017, the U.S. Department of Labor (DOL) submitted to the Office of Management and Budget (OMB) a proposal to delay until July 1, 2019 the implementation date for those portions of the DOL’s fiduciary rule that...more

DOL to Propose Extension of Fiduciary Rule Transition Period

by Morgan Lewis on

The proposal is expected to delay additional conditions of exemptions from January 1, 2018 to July 1, 2019, but the ultimate length of delay will not be clear until the DOL publishes a final rule....more

DOL Seeks Further Delay of ‘Fiduciary Rule’ Exemptions

by Shearman & Sterling LLP on

On August 9, 2017, the Department of Labor notified the District Court of Minnesota that it had submitted to the Office of Management and Budget amendments that would delay until July 1, 2019 the applicability of three...more

DOL Issues Request for Information Regarding Fiduciary Rule

On June 29, 2017, the Department of Labor (“DOL”) issued a Request for Information (“RFI”) in connection with its examination of the Final Fiduciary Rule, which was published on April 8, 2016, and became applicable on June 9,...more

DOL’s Fiduciary Rule Resource Page

by MoFo Reenforcement on

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

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

by Morrison & Foerster LLP on

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

DOL Issues First Guidance on Fiduciary Rule

On October 27, 2016, the U.S. Department of Labor (DOL) issued initial guidance on its new fiduciary rules, which are scheduled to become effective on April 10, 2017. The guidance was issued in the form of FAQs and is...more

The Department of Labor’s 2016 Final Fiduciary and Conflict of Interest Regulations: The Principal Transactions Exemption

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

The DOL’s New Fiduciary Rule: The Details on Disclosure

by Shearman & Sterling LLP on

As discussed in our publication dated April 14, 2016, the final Department of Labor fiduciary rule provides for two new prohibited transaction exemptions, the Best Interest Contract Exemption (the “BIC Exemption”) and the...more

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