On Aug. 31, 2017, the Department of Labor (DOL) announced a proposed 18-month extension from Jan. 1, 2018, to July 1, 2019, for the Fiduciary Rule’s Best Interest Contract (BIC) Exemption and the Principal Transactions Exemption, and certain amendments to Prohibited Transaction Exemption 84-24. Under transition period guidance which delayed implementation of these rules until Jan. 1, 2018, a fiduciary adviser must only comply with the Impartial Conduct Standards of the rules through Dec. 31, 2017. Under the proposed extension, this transition period would be extended until July 1, 2019. In addition, under Field Assistance Bulletin 2017-03, the DOL announced a nonenforcement policy regarding the requirement that these exemptions are not available if a client is required to waive his or her right to participate in a class action and must instead agree to arbitration.
The DOL provides additional information and links to the guidance in its news release issued on Aug. 31, 2017.