With the survival of the US Department of Labor’s (DOL) new fiduciary rule (at least for now) and the applicability date (June 9, 2017) now behind us, plan sponsors who have not already begun to do so should take steps to ensure compliance in light of the changes resulting from the rule. Fortunately, the implementation of certain exemption conditions are phased-in to some extent (from June 9, 2017, to January 1, 2018), and the DOL has announced a temporary “non-enforcement policy” for those fiduciaries who are working diligently and in good faith to comply with the rule and exemptions. This Legal Update focuses on certain aspects of the rule that have implications for plan sponsors, plan committees and employees of plan sponsors who provide services for such plans and summarizes action steps that plan sponsors should consider taking now.
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