The New Fiduciary Rule (39): Qualified Annuity Exchanges
Key Takeaways The DOL’s fiduciary regulation will be effective on September 23 of this year. As a result, beginning on September 23 one-time recommendations to retirement investors can be fiduciary advice and, where the advice is conflicted, the protection afforded by a prohibited transaction exemption will be needed. While some of the requirements (called “conditions”) […]
The New Fiduciary Rule (10): What is An Investment? (Part 2)
The U.S. Department of Labor has released its package of proposed changes to the regulation defining nondiscretionary fiduciary advice and to the exemptions for conflicts and compensation for investment recommendations to retirement plans, participants (including rollovers), and IRAs. The proposed regulation redefines fiduciary status for “investment” recommendations. But what is an investment recommendation? The answer: […]
The New Fiduciary Rule (9): What is An Investment? (Part 1)
The US Department of Labor has released its package of proposed changes to the regulation defining nondiscretionary fiduciary advice and to the exemptions for conflicts and compensation for investment recommendations to retirement plans, participants (including rollovers), and IRAs. The proposed regulation redefines fiduciary status for “investment” recommendations. But what is an investment recommendation? The answer: […]
A Rollover Recommendation Is a Securities Recommendation
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., from a 401(k) account to […]