When the Department of Labor makes the biggest change to fiduciary responsibilities since 1975, it draws people’s attention. Plan sponsors. Financial advisers. Brokers. Attorneys. Recordkeepers. TPAs. Consultants. The SEC. FINRA. Congress. The list goes on and on.
It should have grabbed your attention. Depending on your role, the new guidance will impact you in different ways. For example, if you oversee a plan under $50 million and use a non-fiduciary broker, you will need a new adviser or your broker will have to make significant changes. If you oversee a larger plan, you will see increased disclosures – many of the “CYA” variety – from your providers. And of course, as a plan participant, you will see differences in the way brokers or advisers may interact with you – and the advice they provide you – if you retire or terminate employment, and are considering a rollover.
Within a couple hours of the DOL’s release of more than 1,000 pages of regulations, prohibited transaction exemptions, and commentary, “experts” around the country were willing to tell us exactly what it all means. That may not be as bad as Congress adopting the provisions of the Affordable Care Act without reading the law, but, well you get the point.
So how do we take all of those pages and make it manageable? How do we make it understandable? We carve it up into pieces. We will endeavor to do that with an upcoming six-part series: “The Who, What, When, Where, Why, and How of the Fiduciary Regulation”. We’ll start out of order with the next blog post: “Understanding the Fiduciary Regulation: Why?”