U.S. DoL Delay of Fiduciary Rule

• Provided 18-month delay of applicability date of three exemption provisions in rule.
• Followed August 31, 2017 extension proposal when rule wasn't delayed.
• After a review of comments received, DoL adopted proposed delay without change.

Exemptions Delay

• Extend transition period, delay applicability date from January 1, 2018 to July 1, 2019.
• Delay of applicability included the best interest contract Exemption (PTE 2016-01).
• Covered provision of a class exemption, for principal transactions in certain assets
  between advice fiduciaries, with employee benefit plans and IRAs, (PTE 2016-02).
• Also prohibited trade exemption for insurance agent, brokers, pension consultants,
  insurance companies, and investment company principal underwriters (PTE 84-24).

Impartial Conduct Standard

• May continue to give prudent advice in retirement investors’ best interest, charge
  no more than reasonable compensation, avoid misleading statements by advisers
• Advisers who rely on exemption in period, must meet impartial conduct standards.

Reexamine Fiduciary Rule

• Delay gives DoL time to review changes to the fiduciary rule and PTEs as a result.
• Impact of reexamination is unknown until completion, may give better alternative.
• SIFMA approved delay, said SEC should take the lead in coordination with the DOL
  to develop such a principles-based standard of conduct for the benefit of investors.

Effectiveness

• DoL approved 18-month extension with no change, in November 29, 2017 federal register.