Here is the latest update that came out this week on the DOL Rule. Please be aware that this information is subject to change and if it does, we will then
provide you with updated guidance.
The fiduciary rule, the BIC exemption, and the Principal Transactions Exemption will now become applicable on June 9, 2017 (as opposed to the original
applicability date of April 10, 2017). The extension also amends the transition relief in Section IX of the BIC exemption and Section VII of the Principal
Transactions Exemption to require that, from June 9, 2017 until January 1, 2018, fiduciaries only need to adhere to the impartial conduct standards.
What do you need to do during the transition period - June 9, 2017 to January 1, 2018?
*** Follow the Rule's Impartial Conduct Standards for Brokerage Retirement Accounts ***
1. At the time of a recommendation to a retirement client, provide the client advice in his/her best interest
2. Do not charge/receive unreasonable compensation for retirement accounts
3. Do not make misleading statements about a recommended transaction, fees and compensation, material conflicts of interest and any other matters related
to the retirement client's investment decisions
As most of our advisors are already fiduciaries on the IPI Wealth side, these items are a part of your daily conversations and actions with your clients
today. However, if you have any questions, please give me a call to discuss.
What did the prior Rule require that you will not have to do during the transition period - June 9, 2017 to January 1, 2018?
1. You are not required to tell clients affirmatively that you are acting as a fiduciary with respect to the recommendation.
2. You will not be required to disclose to clients exactly what the impartial standards require.
3. You will not be required to affirmatively state to a client that you complied with the impartial standards in making the recommendation.
4. You will not have to comply with the recordkeeping requirements of the BIC exemption.
These 4 items which were required in the original DOL Rule, clearly show how absurd the original rule was as written. We will continue to monitor the
situation and if there any changes, we will keep you posted.
****If you are currently not a fiduciary (you are not registered with IPI Wealth) and have questions on the impartial conduct standards, please call
me to set up a time to discuss this further. Thanks, Renee