On June 29, 2017, the Department of Labor (“DOL”) issued a Request for Information (“RFI”) in connection with its examination of the Final Fiduciary Rule, which was published on April 8, 2016, and became applicable on June 9, 2017. 

The RFI was issued in response to President Trump’s February 3, 2017, memorandum directing the DOL to prepare an updated analysis of the likely impact of the Fiduciary Rule on access to retirement information and financial advice. The RFI was released in the same week that Secretary Acosta of the DOL and Chairman Clayton of the SEC pledged to work together to address the Fiduciary Rule.

The RFI is broad in scope and will likely generate a wide range of responses, many of which will be of interest to market participants in the structured products sector. Accordingly, as many observers have noted, a variety of aspects of the new rules may be subject to change; the form of the final version may not be knowable at this time but may vary significantly from the rules that were originally enacted.

To read our blog post on the RFI, please click here.