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ARTICLE · 18 AUGUST 2017

DOL Issues Additional Fiduciary Rule Transition FAQs

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

United StatesEmployment and HR

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

The US Department of Labor (DOL) has released an additional set of three frequently asked questions (FAQs) to address further inquiries in light of the applicability of the fiduciary rule on June 9. This guidance is in addition to several prior sets of FAQs issued by the DOL to clarify the DOL's fiduciary rule and related exemptions.

Analysis of the FAQs

The new set of FAQs, issued August 4, 2017, addresses the fiduciary rule's impact on other required disclosures of covered service providers to ERISA plans (as opposed to non-ERISA plans, such as IRAs) under ERISA Section 408(b)(2) ("service provider fee disclosures") during the transition period that began on June 9, 2017, and whether certain recommendations constitute fiduciary investment advice. Specifically, the FAQs address:

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