ML BeneBits

There continue to be developments on the Department of Labor’s (DOL’s) fiduciary rule. Recently, additional fiduciary rule transition FAQs were published, providing guidance on 408(b)(2) disclosure issues and when communications on plan or IRA contributions do not constitute fiduciary investment advice. The DOL also has taken action to propose an extension of the fiduciary rule transition period, which is expected to further postpone the applicability of the additional conditions of certain exemptions from January 1, 2018 to July 1, 2019 (subject to clearance from the Office of Management and Budget, publication of a proposed notice in the Federal Register, and a comment period).

We will keep you informed of further developments in this area.