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US Tax Reform Impacts Roth Individual Retirement Account Conversions

HR 1 makes Roth IRA conversion recharacterizations a thing of the past, but is silent on whether recharacterizing 2017 Roth IRA conversions in 2018 will be permitted....more

It’s Official! DOL Finalizes Delay

The Fiduciary Rule transition period is extended until mid-2019, with financial institutions having flexibility in complying with the impartial conduct standards during this period....more

Extension of Fiduciary Rule Transition Period Likely Official End of November

Thrivent wins injunction on anti-arbitration clause. Update on the Fiduciary Rule Delay - On November 1, the White House Office of Management and Budget (OMB) received a much-anticipated notice from the US Department of...more

11/13/2017  /  Arbitration , Fiduciary Rule , OMB

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

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 Issues Additional Fiduciary Rule Transition FAQs

The Department of Labor ties up a few loose ends with FAQS regarding the fiduciary rule....more

DOL to Propose Extension of Fiduciary Rule Transition Period

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 Fiduciary Rule: Ready, Set, Go! But How Far?

The DOL has issued transition FAQs and a nonenforcement policy—meanwhile, here comes the SEC....more

DOL Fiduciary Rule—Slowed Down, but Not Out

The rule is delayed by 60 days, with core elements taking effect June 9 as the DOL conducts a study. The Department of Labor (DOL) has issued in final form its eagerly awaited delay of changes to the fiduciary investment...more

Fiduciary Rule—Not Delayed Yet

60-day delay proposed, comments requested on president’s study. The US Department of Labor (DOL) has proposed to delay the applicability date of the fiduciary rule (and related prohibited transaction exemptions) by 60...more

President Trump Issues Memorandum on DOL Fiduciary Duty Rule

Memorandum does not delay applicability date—but is it enough for firms to stand down? Anxiously awaited by many in the financial services industry, President Donald Trump has issued a memorandum ordering the Department...more

Two New Sets of DOL Fiduciary Rule FAQs

DOL releases additional guidance on fiduciary rule in the waning days of the Obama administration. The US Department of Labor (DOL) has released two new sets of frequently-asked-questions (FAQs) regarding the conflict of...more

New Guidance Restores 1994 ERISA Proxy Voting Interpretation

The DOL bulletin also clarifies the ability to consider ESG factors in proxy voting and shareholder engagement. On December 29, 2016, the Department of Labor (DOL) issued Interpretive Bulletin 2016-1 (IB 2016-1),...more

The 2016 Election and the Future of the Department of Labor Fiduciary Rule

The election of Donald J. Trump to be the 45th president of the United States and Republican control of both congressional houses could have profound impacts on financial services regulation, including the fiduciary...more

Fiduciary Rule FAQs Challenge Back-End Recruitment Bonuses

Financial services firms with active recruiting programs should consider immediately how the DOL’s FAQs affect their compensation packages with respect to back-end recruitment awards. To help the financial services...more

DOL Releases First Wave of FAQs on Fiduciary Rule

The guidance is the first of three waves of FAQs. On October 27, the US Department of Labor (DOL) released a long-awaited frequently asked questions (FAQs) document regarding the fiduciary rule, as released on April 8,...more

Final DOL Fiduciary Rule—First Impressions

Final rule includes many changes and clarifications intended to address concerns raised about the proposal, but issues remain. The US Department of Labor (DOL) has released its final regulation “Definition of the Term...more

DOL Sends Fiduciary Rule to OMB for Review

DOL has indicated that the final rule will be released in the first half of the year. The US Department of Labor (DOL) sent its final Conflict of Interest Rule—Investment Advice (with related exemptions and amendments to...more

DOL’s Proposal To Expand Fiduciary Definition Would Bring Many Service Providers Into Scope

As we previously reported, the US Department of Labor (DOL) released its reproposed rule “Definition of the Term ‘Fiduciary’; Conflict of Interest Rule—Investment Advice” on April 14. The initial deadline for comments on the...more

Department of Labor Retirement Initiative Fails to Consider Current Regulatory Regime, which Comprehensively Protects Investors,...

We have prepared this white paper to address errant claims made in the Council of Economic Advisers’ (CEA) report, “The Effects of Conflicted Advice on Retirement Savings” (CEA Report), regarding perceived inadequacies in the...more

DOL Sends Proposed Conflict of Interest Rule to OMB for Review

The White House backs a “fiduciary rule” for IRAs. The U.S. Department of Labor (DOL) has sent its proposed “Conflict of Interest Rule-Investment Advice” to the president’s Office of Management and Budget (OMB) for...more

DOL Proposes Amendment to Service Provider Fee Disclosure Regulation

Proposal would require certain service providers to furnish a separate disclosure guide. On March 11, the U.S. Department of Labor (DOL) issued a proposed amendment to its 2012 final regulations under section 408(b)(2)...more

FINRA and SEC to Focus on IRA Rollover Practices in 2014

Financial institutions should prepare for increased regulatory scrutiny. The Financial Industry Regulatory Authority (FINRA) and the U.S. Securities and Exchange Commission (SEC) released their examination priorities...more

DOL Clarifies Application of ERISA Rules to Cleared Swaps

New guidance defers to the Dodd-Frank/CFTC framework for regulating the swaps clearing process. On February 7, the U.S. Department of Labor (DOL) issued an advisory opinion on the application of the ERISA fiduciary rules...more

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