This is my fifth article about interesting observations “hidden” in the preambles to the fiduciary regulation and the exemptions. The Best Interest Contract Exemption (BICE) has a special exemption for “level fee fiduciaries” who recommend to plan participants that they take distributions and rollover to an IRA advised by the
This is my fourth article about interesting observations “hidden” in the preambles to the fiduciary regulation and the exemptions. During a recent webinar for TD Ameritrade, one of the attendees asked if Jim Cramer’s TV stock tips would be considered fiduciary advice. I said that they would not be, since
This is my third article about the interesting observations “hidden” in the preambles to the fiduciary regulation and the exemptions. Under the Best Interest Contract Exemption (BICE), the “financial institution” (e.g., a broker-dealer) cannot pay a fiduciary adviser (e.g., a financial adviser) incentive compensation that would encourage an adviser to
This is my second article about the interesting observations “hidden” in the preambles to the fiduciary regulation and the exemptions. The recommendation of investments and insurance products to plans, participants, and IRAs will be subject to the best interest standard of care. (The best interest standard is a combination of
While you have probably read articles that summarize the DOL’s final fiduciary rule and exemptions—and perhaps even articles that discuss specific aspects of the rules, there are a number of interesting observations “hidden” in the preambles to the regulation and exemptions. In many cases, those comments are so focused on
Please join Brad Campbell and me during the April 28, 2016 presentation of “Inside the Beltway,” at noon eastern/9 am pacific time. Inside the Beltway is a quarterly audiocast in which we discuss developments in Washington that directly impact our industry. During this sixteenth presentation of Inside the Beltway we
The DOL’s fiduciary rule has been published in the Federal Register. Based on our review of the regulation and conversations with our clients, here are some overview thoughts about the regulation and the two “distribution” exemptions (84-24 and BICE). The Fiduciary Definition The rule is much as expected. The definition
As I work with broker-dealers and RIA firms, certain patterns are developing in their efforts to satisfy the requirements of the DOL’s fiduciary rule and the exemptions. This article looks at some of those “solutions” and comments on the areas where there is some agreement . . . or at
After my last post, I was asked another question about distributions and rollovers under the DOL’s proposed fiduciary regulation. Here’s the question and my answer: Question: One thing I have heard is that all IRA Rollovers will fall under the DOL ERISA fiduciary standards with this rule. Have you heard
A reporter recently asked me to explain why people are saying that, under the DOL’s fiduciary proposal, an adviser should not recommend that a participant take a distribution and roll over to an IRA, but instead should provide distribution education. Here’s my answer: There are two issues. The first is
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