As has been widely reported, the U.S. Department of Labor (DOL) on April 14 issued its proposal to expand the definition of investment advice fiduciary under the Employee Retirement Income Security Act (ERISA). DOL included in that package more than 170 questions concerning its proposal or matters left open in that proposal. In the usual manner, that approaches both:
- Constructively solicits input from the regulated community, and
- Makes that input less informed and useful because significant elements of the proposal are open ended
Because many of the questions involve key issues, particularly under the expanded fiduciary definition and the proposed Best Interest Contract Exemption, they are collected below.
Click here to view table.