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
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
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?
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
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
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
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,
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
This is my twenty-third article about interesting observations concerning the fiduciary rule and exemptions. When the definition of fiduciary advice is expanded on April 10, 2017, the investment and insurance recommendations of a much larger group of advisers will be classified as fiduciary advice and will, as a result, increase
This is my twenty-second article about interesting observations concerning the fiduciary rule and exemptions. While the application of the new fiduciary rule and prohibited transaction exemptions to broker dealers and investment advisers is fairly obvious — if not fully understood, there has been little in the way of discussion about
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