News & Analysis as of

IRA Rollovers Individual Retirement Account (IRA) Financial Institutions

Faegre Drinker Biddle & Reath LLP

Things I Worry About (10): FINRA Enforcement and Senior Investors (2)

Key Takeaways - FINRA’s 2025 Annual Regulatory Oversight Report 2025-annual-regulatory-oversight-report.pdf included a focus on issues related to retirees and senior investors. - The Report provides guidance to...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #100: Liabilities and Opportunities

The DOL’s expanded definition of fiduciary advice is explained in the preamble to PTE 2020-02. When conflicted fiduciary advice is given to retirement investors, that is, retirement plans, participants (including...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #99: The PTE 2020-02 Requirement for An Annual Retrospective Review

The DOL’s expanded definition of fiduciary advice is explained in the preamble to PTE 2020-02. When conflicted fiduciary advice is given to retirement investors (that is, retirement plans, participants (including rollovers),...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #98: How PTE 2020-02 Impacts Advice to IRAs

The DOL’s expanded definition of fiduciary advice to retirement plans, participants, and IRAs was described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations to...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #97: The SEC Requirements for Rollover Recommendations

The DOL’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. When conflicted fiduciary advice is given to retirement investors (that is, retirement plans, participants (including rollovers),...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #96: Annuity Recommendations, PTE 84-24, and Fiduciary Misunderstandings

The DOL’s expanded interpretation of fiduciary advice is described in the preamble to Prohibited Transaction Exemption (PTE) 2020-02. The expanded interpretation applies to all rollover recommendations, including...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #95: The Four Effective Dates for PTE 2020-02

The DOL’s expanded interpretation of fiduciary advice is described in the preamble to Prohibited Transaction Exemption (PTE) 2020-02. When conflicted fiduciary advice is given to retirement investors (that is, retirement...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #94: Maintenance of Documentation for Compliance with PTE 2020-02

The DOL’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. When conflicted fiduciary advice is given to retirement investors (that is, retirement plans, participants (including...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #92: Consideration of Costs in the Evaluation of Rollovers

The DOL’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations (for example, rollover recommendations), if its...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #91: Rollover Recommendations to Participants in Government Plans

The DOL’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations (for example, rollover recommendations), if its...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #90: Rollover Recommendations to Participants in Defined Benefit Plans

The DOL’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations (for example, rollover recommendations), if its...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #89: Rollovers and the Information That Is Needed About the Participant

The DOL’s expanded definition of fiduciary advice was described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations (for example, rollover recommendations), if its...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #88: Specific Reasons for Rollover Recommendations That Won’t Work (Part 2)

The DOL has issued FAQs that generally explain PTE 2020-02 and the expanded definition of fiduciary advice, particularly for rollover recommendations. The DOL’s expanded definition of fiduciary advice was described in the...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #87: Specific Reasons for Rollover Recommendations That Won’t Work (Part 1)

The DOL has issued FAQs that generally explain PTE 2020-02 and the expanded definition of fiduciary advice, particularly for rollover recommendations. The DOL’s expanded definition of fiduciary advice was described in...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #86: Information Needed for Rollover Recommendations

The DOL has issued FAQs that generally explain PTE 2020-02 and the expanded definition of fiduciary advice, particularly for rollover recommendations. The DOL’s expanded definition of fiduciary advice was described in the...more

Faegre Drinker Biddle & Reath LLP

SLOW Your Roll: DOL Temporarily Halts Enforcement of Compliance with PTE and ERISA Fiduciary Obligations for Rollover Advice

Benjamin Franklin once said “don’t put off until tomorrow what you can do today.” While that is always prudent advice, the Department of Labor (DOL) believes it’s best to grant an extension to investment advisors and...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #75: Compliance with PTE 2020-02: Mitigation of Conflicts (Part 2)

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - Key Takeaways - ◾ The DOL has issued FAQs that generally explain PTE 2020-02 and the expanded definition of fiduciary advice. ◾ In FAQ 16, the DOL...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #74: Compliance with PTE 2020-02: Mitigation of Conflicts (Part 1)

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - Key Takeaways - ◾ The DOL has issued FAQs that generally explain PTE 2020-02 and the expanded definition of fiduciary advice. ◾ In FAQ 16, the DOL...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #73: Compliance with PTE 2020-02: IRA “Rollovers” Are Covered by the Rule, But What is...

This series focuses on the DOL’s new fiduciary “rule”, which was effective on February 16. This, and the next several, articles look at the Frequently Asked Questions (FAQs) issued by the DOL to explain the fiduciary...more

Bradley Arant Boult Cummings LLP

Year-End Regulatory Relief for Investment Advisors: DOL Further Delays Enforcement of PTE 2020-02

The Department of Labor (DOL) has issued Field Assistance Bulletin No. 2021-02 to further delay enforcement of Prohibited Transaction Exemption 2020-02 (PTE 2020-02), which sets forth several requirements that financial...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #70: Compliance with PTE 2020-02: Factors to Evaluate for an IRA-to-IRA Rollover...

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - This series focuses on the DOL’s new fiduciary “rule”, which was effective on February 16. This, and the next several, articles look at the Frequently...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #69: Compliance with PTE 2020-02: Factors to Evaluate for an IRA-to-IRA Rollover...

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - This series focuses on the DOL’s new fiduciary “rule”, which was effective on February 16. This, and the next several, articles look at the Frequently...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #57

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - This series focuses on the DOL’s new fiduciary “rule”, which was effective on February 16. This, and the next several, articles look at the Frequently...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #56

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: The FAQs - This series focuses on the DOL’s new fiduciary “rule”, which was effective on February 16. This, and the next several, articles look at the Frequently...more

Faegre Drinker Biddle & Reath LLP

Best Interest Standard of Care for Advisors #54

The Department of Labor’s “Fiduciary Rule,” PTE 2020-02: An Overview - This article is an overview of the requirements of PTE 2020-02. It discusses the expanded fiduciary definition, the conditions in the PTE, and the...more

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