Preliminary Views and Rule Interpretation

On April 6, 2016, the U.S. Department of Labor (DOL) released its final Conflict of Interest (“Fiduciary”) Rule.

The Rule and related Prohibited Transaction Exemptions (PTEs) are substantial documents - in part due to the volume of background provided by the DOL on their deliberations around the range of comments received during the proposed rule’s notice period. 

We are still poring over and reflecting on the Rule provisions and will continue to do so in the days and weeks ahead.  In addition, we will be engaging heavily with other industry participants to exchange perspectives on impacts.  In the meantime, we wanted to provide you with our preliminary reactions and early hypotheses as to the implications of the final versus proposed Rule (issued April 20, 2015).

Preliminary Views and Rule Interpretation