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Nevin & Fred: What to Do When You Didn’t Do What You Were Supposed to Do

Regulatory Compliance

With the written best interest documentation requirement now in place (as of July 1), and with some evidence that some advisors might not have focused on that deadline (or a series of others that took effect in February), in this episode Nevin (Adams) & Fred (Reish) look at some new ways to “fix” non-compliance issues.

Basically, 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.

As part of that, in a previous episode we noted that there were some “new” rules with rollovers—and a new requirement that kicks in July 1. But what if you (or your firm) missed that date—or the others that became effective in February?  In this episode, we cover those aspects—as well as a couple of other new developments!

Episode Resources

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