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Are Your Rollover Recommendations ‘Ready’?

Regulatory Compliance

As you all (hopefully) know, there are some new rules regarding rollover recommendations—notably the requirement to document—in writing—why a rollover is in the participant’s best interest. This week—if you work with rollovers—or if you’re thinking about it—we’d like to know what you think.

That’s right, the Labor Department’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations (for example, rollover recommendations), if its conditions are satisfied. 

Specifically, if investment advice involves a rollover recommendation, in addition to several other requirements under PTE 2020-02, financial advisors must:

  • document the reasons that a rollover recommendation is in the best interest of the retirement investor; and 
  • disclose the justification for the rollover in writing to the retirement investor.

This week, we’d like to know if you do rollovers, and if you do, if/when you/your firm started complying with the new regulations.  

REPLY to this week’s NAPA-Net Reader Radar poll at https://www.research.net/r/72JSLHH.

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