On April 4, 2017, less than a week before the scheduled
applicability date, the Department of Labor (the "DOL")
announced a 60-day extension of its fiduciary guidance published
April 8, 2016: the revised definition of a fiduciary under the
Employee Retirement Income Security Act ("ERISA") (the
"Fiduciary Rule"), the new Best Interest Contract
Exemption ("BIC Exemption"), and Principal Transactions
Exemption and revisions to PTE 84-24, PTE 86-128, and other
previously granted exemptions affected by the Fiduciary
Rule.
Taking into account this delay, the Fiduciary Rule, the BIC
Exemption, and the Principal Transactions Exemption will apply as
of June 9, 2017, but will initially require fiduciaries only to
meet the Impartial Conduct Standards, but not the documentation,
disclosure, and other conditions of the PTEs. The Impartial Conduct
Standards include providing advice in the investor's best
interest, charging no more than reasonable compensation, and
avoiding
