The expanded fiduciary definition in DOL PTE 2020-02 is effective now, and until January 31, 2022, RIAs can rely on the Impartial Conduct Standards for rollover and transfer recommendations (and for other conflicts resulting from nondiscretionary advice). However, there are additional, significant conditions in DOL PTE 2020-02 that become effective February 1, 2022, including new disclosures and policies and procedures. Our panelists will discuss those requirements and provide practical insights into developing an action plan for compliance with the new PTE, including steps RIAs should take to:
- Develop a best interest process for rollovers
- Consider alternatives to covered “recommendations”
- Adopt disclosures, policies and procedures to ensure compliance
- Conduct the required annual retrospective reviews
The specific documentation and disclosure requirements for rollovers become effective July 1, 2022. However, the rest of these changes need to be in place before February 1, 2022, and therefore, time is of the essence.
Questions? Please contact Heather Sanders or call +1 215 988 1127.