Each calendar quarter, I post approximately 12 articles on my blog, fredreish.com. This quarterly digest provides links to the most popular posts during the past three months so that you can catch up on what you missed or re-read them. A Rollover Recommendation is a Securities Recommendation The Department of
Key Takeaways The Department of Labor considers a rollover recommendation to be a recommendation to liquidate the investments in a participant’s 401(k) account or to transfer (and change) securities. In addition, as explained in earlier articles, the DOL considers a plan-to-IRA rollover to be a change of account type, e.g.,
Regulation Best Interest: SEC 2020 Examination Priorities—Examinations for Compliance With Reg BI and the Investment Adviser Interpretation The SEC has issued its final Regulation Best Interest (Reg BI), Form CRS Rule, RIA Interpretation and Solely Incidental Interpretation. I am discussing the SEC’s guidance in a series of articles entitled “Best
FINRA is taking the position that broker-dealers need to evaluate the long-term costs of different share classes in 529 plans. In effect, FINRA is imposing a “best interest” standard on 529 recommendations. For a description of FINRA’s expectations and its new self-disclosure program, here is an article by several of
I am writing two series of articles that together are called “The Bests.” One is about Best Practices for plan sponsors, while the other is about the Best Interest Standard of Care for advisors. Each series is numbered separately to make it easier to identify the subject that is most
Investment Advisers and the SEC’s Interpretation of Their Duties: Part II This is my 100th article about interesting observations—or “angles”—concerning the Department of Labor’s Fiduciary Rule and the SEC’s “best interest” proposals. Part I of this post discussed the application of the SEC’s best interest standard to recommendations to participants
SEC Proposed Reg BI and Recommendations of Rollovers (Part 3) This is my 94th article about interesting observations concerning the Department of Labor’s (DOL) fiduciary rule and exemptions and the SEC’s “best interest” proposals. Part 1 of this series discussed the provisions in the SEC’s proposed Regulation Best Interest that
SEC Proposed Reg BI and Recommendations of Rollovers (Part 2) This is my 93rd article about interesting observations concerning the Department of Labor’s (DOL) fiduciary rule and exemptions and the SEC’s “best interest” proposals. In my last post, I described the similarities between the SEC proposed Regulation Best Interest (Reg
SEC Proposed Reg BI and Recommendations of Rollovers (Part 1) This is my 92nd article about interesting observations concerning the Department of Labor’s (DOL) fiduciary rule and exemptions and the SEC’s “best interest” proposals. On April 18, 2018, the SEC released three proposals for comment—Regulation Best Interest (“Reg BI”) for
Parallels Between the SEC Regulation Best Interest and the DOL Best Interest Contract Exemption (Part 1) This is my 90th article about interesting observations concerning the Department of Labor’s (DOL) fiduciary rule and exemptions. These articles also cover the DOL’s FAQs interpreting the regulation and exemptions and related developments in
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