This client alert, written by Fred Reish, Bruce Ashton, Brad Campbell, Joan Neri, and Josh Waldbeser, from the Drinker Biddle Employee Benefits and Executive Compensation Group, summarizes our conclusions about the impact on participant investment “recommendations” of the Department of Labor (DOL) proposal to expand the definition of fiduciary investment advice. We
This client alert, written by Fred Reish, Bruce Ashton, Brad Campbell, Joan Neri, and Josh Waldbeser, from the Drinker Biddle Employee Benefits and Executive Compensation Group, states our conclusions about the impact of the Department of Labor (DOL) proposal to expand the definition of fiduciary investment advice and to modify prohibited transaction (PT)
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The allocation of revenue sharing in 401(k) plans is a fiduciary decision. We explored that issue in detail in a recent white paper. We also looked at the concept of lowest “net” expense ratios. We concluded that there were fiduciary risk management benefits to “equalizing” revenue sharing (that is, returning
By now, you’ve probably read about some of the details of the Department of Labor’s fiduciary proposal. This article isn’t about the details; it’s about the essence. What’s the big picture? First, the proposal significantly expands the definition of fiduciary advice. As a result, almost every person who makes an
Over the last few months, the most common questions asked by clients . . . and most of my work . . . have been about three issues: The DOL’s new fiduciary proposal . . . not surprising. Capturing rollovers from retirement plans. Again, not surprising because of the large
The hottest ERISA issue of 2015 is the DOL’s proposal to expand the definition of fiduciary advice. That proposal has become highly publicized because of the White House endorsement and the aggressive Wall Street opposition. Unfortunately, political rhetoric on both sides has dominated the discussion . . . to the
Insurance guarantees for retirement benefits — such as annuities, QLACs, and GMWBs—are increasing in popularity . . . because they guarantee that the money lasts for a lifetime. However, there is not much guidance about the fiduciary process for selecting a particular annuity or GMWB product to provide those guaranteed
I recently wrote an article for JP Morgan about the fiduciary process for implementing investment policy statements . . . with particular emphasis on the monitoring of investments and investment managers in participant-directed plans. The article outlines a step-by-step approach for identifying investments to be placed on a watch list,
Little has been written about how a plan fiduciary should prudently select insurance companies and guaranteed retirement income for participants. There’s a DOL “safe harbor” regulation, but it doesn’t give fiduciaries a checklist for compliance. To address this, Lincoln Financial hired us to work with an insurance consultant to develop
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