Stop Waiting – The DOL Fiduciary Rule Implementation is June 9th
Memorial Day weekend will feel more like Labor Day Weekend for firms who have been taking a “wait and see” approach to the DOL Fiduciary Rule. Labor Secretary Alexander Acosta confirmed last night that the DOL Fiduciary Rule will not be delayed beyond June 9th. While CCOs who have created, implemented and trained the field on the Impartial Conduct Standards are celebrating the unofficial beginning of Summer, procrastinators will likely be united in editing policy and procedure manuals and working on training and communications to make sure their firms are fully compliant with the applicable standards. Here are some things to keep in mind regarding those standards:
- The expanded definition of fiduciary investment advice will go into effect on June 9th.
- The Best Interest Contract Exemption (BICE) will be available to fiduciaries on June 9th.
- The Impartial Conduct Standards must be adhered to beginning on June 9th by those fiduciaries relying on the BICE
- The other BICE conditions do not have to be met prior to January 1, 2018.
- Included among the Impartial Conduct Standards are the requirement to act in the best interest of retirement investors, compensation cannot be in excess of reasonable compensation and statements made to retirement investors cannot be materially misleading at the time they are made.
While the Best Interest Contract Exemption and other aspects of the rule may be adjusted going forward, the time for action to achieve compliance is now.
Oyster can assist your firm as it navigates the new Fiduciary Rule changes. For more information about how Oyster Consulting can help, complete our contact form or call us at 804.965.5400 and one of our Relationship Managers will be happy to help you.