Posts from March 2017.

The IRS released guidance this week announcing that it will not apply IRC § 4975 excise taxes (15% on prohibited transactions) and related reporting requirements "with respect to any transaction or agreement to which the DOL's temporary enforcement policy, or other subsequent related enforcement guidance, would apply."

On March 13, DOL issued its Field Assistance Bulletin saying it would forbear enforcement of the Fiduciary Duty Rule if Labor hasn't finished its review by the April 10 effective date. The review (and potential delay in implementation) of the Rule was ordered by an ...

Posted in: Fiduciary Rule

The Department of Labor's "fiduciary duty" Rule continues to get more bollixed up. DOL announced a temporary enforcement policy that will give a "free pass" for any violations (a) in the gap between effective date and delay, or (b) tardy good-faith compliance if there's no delay.

The Rule becomes effective on April 10, requiring among others a fiduciary acknowledgement (even though full BIC contract compliance won't be required until January 1, 2018). DOL published a proposed delay for 15-day comment on March 2, with a broader "merits" comment period extending thereafter. If ...

Posted in: Fiduciary Rule


The two remaining SEC Commissioners agreed March 1 to propose amendments "requiring" municipal securities issuers to disclose non-security financial obligations and material events occurring in other outstanding obligations.

The Municipal Securities Rulemaking Board ("MSRB") and other market participants have argued for years that undisclosed bank loans, direct participations, and material events occurring with an issuer's other outstanding obligations remained "blind spots" to market transparency, and to investors' ability to evaluate issuers' financial status ...

Posted in: SEC

The US Department of Labor today proposed a 60-day extension (through June 9) for the effective date of its Fiduciary Duty Rule and related exemptions.

The extension would give DOL some time to complete the re-analyses directed in the President's February 3 Memo. The Memo directs DOL to examine whether the Rule "may adversely affect access to retirement advice and requires an updated economic and legal impact analysis. We discussed that Memo here: 2017/02/09/dol-fiduciary-rule-still-april-10-implementation/

The Department will collect public comment on the proposed ...

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