Policies Under the Fiduciary Rule
Los Angeles partner Fred Reish and Florham Park counsel Joan Neri co-authored an article for PlanAdviser magazine discussing the updates that advisers should make to their policies and procedures to address conflicts of interest under the DOL fiduciary rule. The article explains how failure to do so could make it more difficult to prove compliance with the Best Interest Contract Exemption and could be viewed as an indication that the adviser is not making good faith and diligent efforts to comply with the fiduciary rule.
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