The U.S. Department of Labor (DOL) has filed a proposal with the Office of Management and Budget (OMB) to delay implementation of the following exemptions under the fiduciary rule from January 1, 2018 to July 1, 2019:

  • Best Interest Contract Exemption (PTE 2016-01)
  • Class Exemption for Principal Transactions in Certain Assets Between Investment Advice Fiduciaries and Employee Benefit Plans and IRAs (PTE 2016-02)
  • Prohibited Transaction Exemption 84-24 for Certain Transactions Involving Insurance Agents and Brokers, Pension Consultants, Insurance Companies, and Investment Company Principal Underwriters (PTE 84-24)

This development was publicized by the DOL in a notice of administrative action submitted by its attorneys to the U.S. District Court for the District of Minnesota in one of several antifiduciary rule cases currently pending. Notification of the submission to the OMB becomes publicly available the morning following the submission, which will bring additional details to this delay.

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Photo of Alisha Sullivan Alisha Sullivan

Alisha Sullivan focuses her practice on employee benefits as a member of Robinson+Cole’s Employee Benefits and Compensation Group. Ms. Sullivan helps clients comply with laws governing employee benefit plans. She advises and supports clients on a range of programs, such as pension plans…

Alisha Sullivan focuses her practice on employee benefits as a member of Robinson+Cole’s Employee Benefits and Compensation Group. Ms. Sullivan helps clients comply with laws governing employee benefit plans. She advises and supports clients on a range of programs, such as pension plans, profit-sharing plans, 401(k) plans, health and welfare benefit plans, and compliance with HIPAA and health care reform. Ms. Sullivan handles matters related to the Employee Retirement Income Security Act (ERISA). Read her full rc.com bio here.