In completing its broker-dealer standard of conduct rulemaking, the SEC addressed important questions about the applicability of those requirements to retirement accounts. This alert provides analysis of the reach of the new requirements in the retirement market, including:
- the types of broker-dealer interaction with plan participants that fall within the reach of Regulation Best Interest and Form CRS
- how the new rules deal with the treatment of rollover advice to plan participants and IRA owners
- practical considerations regarding the distinction between “investment education” and “recommendations”