Category: BICE

Interesting Angles on the DOL’s Fiduciary Rule #32

What “Level Fee Fiduciary” Means for Rollover Advice This is my 32nd article about interesting observations concerning the Department of Labor’s fiduciary rule and exemptions. These articles also cover the DOL’s FAQs interpreting the regulation and exemptions. As explained in article #30 in the Angles series, in order to use

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Interesting Angles on the DOL’s Fiduciary Rule #31

“Un-levelizing” Level Fee Fiduciaries This is my 31st article about interesting observations concerning the Department of Labor’s fiduciary rule and exemptions. These articles also cover the DOL’s FAQs interpreting the regulation and exemptions. In the last article I posted, I discussed the three meanings of “Level Fee Fiduciary.” This article

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Interesting Angles on the DOL’s Fiduciary Rule #30

Three Kinds of Level Fee Fiduciaries . . . and What’s A “Level Fee?” This is my 30th article about interesting observations concerning the Department of Labor’s fiduciary rule and exemptions. These articles also cover the DOL’s FAQs interpreting the regulation and exemptions. The DOL’s use of the phrase “Level

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Interesting Angles on the DOL’s Fiduciary Rule #29

Capturing Rollovers: What Information is Needed? This is my 29th article about interesting observations concerning the Department of Labor’s fiduciary rule and exemptions. These articles also cover the DOL’s FAQs interpreting the regulation and exemptions. The Department of Labor’s fiduciary regulation provides that a recommendation to take a distribution from

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The Presidential Election: Now What?

One of the consequences of the presidential election is that the future of the fiduciary rule (and the exemptions) is uncertain. What does that mean to advisers . . . regardless of whether they are representatives of RIAs or broker-dealers, or for that matter, if they are independent insurance agents?

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Interesting Angles on the DOL’s Fiduciary Rule #28

What About Rollovers that Aren’t Recommended? This is my twenty-eighth article about interesting observations concerning the Department of Labor’s fiduciary rule and exemptions. These articles also cover the DOL’s FAQs interpreting the regulation and exemptions. Under the DOL’s fiduciary regulation, the recommendation of a plan distribution and IRA rollover will

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Interesting Angles on the DOL’s Fiduciary Rule #27

The Definition of Compensation This is my twenty-seventh article about interesting observations concerning the fiduciary rule and exemptions. As the readers of these articles know, one impact of the new fiduciary rule is that compensation paid to Financial Institutions and advisers must be reasonable. Reasonable, in turn, is a function

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Interesting Angles on the DOL’s Fiduciary Rule #26

Reasonable Compensation for IRAs: When and How Long? This is my twenty-sixth article about interesting observations concerning the fiduciary rule and exemptions. This article is a little different than most of my previous posts. However, it is equally as important. To get to the point, I am writing this article

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Interesting Angles on the DOL’s Fiduciary Rule #25

Reasonable Compensation Versus Neutral Factors This is my twenty-fifth article covering interesting observations about the fiduciary rule and exemptions. In my last post, I wrote about the Best Interest Contract Exemption (BICE) and the requirements for “neutral factors” and “differential compensation” between “reasonably designed investment categories.” As I pointed out,

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Interesting Angles on the DOL’s Fiduciary Rule #24

The Meaning of Differential Compensation Based on Neutral Factors This is my twenty-fourth article covering interesting observations about the fiduciary rule and exemptions. The DOL’s fiduciary “package” consists of a regulation that expands the definition of advice and exemptions, or exceptions, from the prohibited transaction (PT) rules. If a recommendation

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