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: