The Institute signed onto a letter to the Department of Labor that requests an extension of the comment period from 30 days to 90 days for the submission of public comments on the notice of DOL’s proposed rulemaking entitled “Improving Investment Advice for Workers & Retirees,” (ZRIN 1210-ZA29).
The rulemaking raises many complex and highly technical issues. For example:
- How the reinstatement of the 1975 five-part test for determining who is an investment advice fiduciary will impact retirement savers and providers of retirement investment advice;
- How the proposed exemption would interact with the reinstated definition of investment advice fiduciary;
- How the proposed exemption’s conditions would be satisfied by various firms;
- How firms’ implementation would affect retirement savers, directly and indirectly; and
- How the exemption’s conditions would be interpreted and enforced.
Read the full letter.