The Department of Labor (DOL) extended until July 1, 2019, the date for compliance with the full conditions in its new \u201cinvestment
\nadvice\u201d fiduciary definition and related exemptions (Final Rule), which became generally applicable on June 9.\u00a0 After considering the commentary it received, DOL has extended the Transition Period as proposed, without change. Thus, the same transition rules and standards in effect on June 9 will remain in effect until July 1, 2019.\u00a0 Of particular note, the DOL explained that:
\n\u2022 It needs more time to \u201ccarefully and thoughtfully review\u201d the commentary it has received and to honor the\u00a0President\u2019s directive, as well as to coordinate with the SEC, FINRA, NAIC and other regulators.
\n\u2022 It anticipates proposing a new streamlined class exemption in the near future, which presumably would\u00a0address innovative products being developed in response to the Final Rule.
\n\u2022 It \u201csees no compelling reason\u201d to further extend the \u201cgrandfathering exemption\u201d (although it did solicit\u00a0supplemental comments on this point going forward). The applicability date for determining whether a transaction may be grandfathered remains June 9, 2017.<\/p>\n
Read More Here<\/a><\/p>\n Additional contributor to this post:<\/p>\n W.\u00a0Mark Smith<\/a>,\u00a0marksmith@eversheds-sutherland.com<\/a><\/p>\n","protected":false},"excerpt":{"rendered":" The Department of Labor (DOL) extended until July 1, 2019, the date for compliance with the full conditions in its new \u201cinvestment advice\u201d fiduciary definition and related exemptions (Final Rule), which became generally applicable on June 9.\u00a0 After considering the commentary it received, DOL has extended the Transition Period as proposed, without change. Thus, the … Continue reading The Final Rule: Considerations and Analysis of the DOL\u2019s 18-Month Transition Period Extension<\/span>