"DOL Fiduciary and the Super Bowl: No Delay of Game (Yet) and Overtime Possible"

On Friday, President Trump issued a  Memorandum to the Secretary of Labor concerning the investment advice “fiduciary” rule under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), which is scheduled to be “applicable” on April 10 (the “Fiduciary Duty Rule”).
As the exciting Super Bowl LI game showed – even in an apparent blow out in the fourth quarter – there can be surprises.   The final text of the Memorandum differs in some material respects from the text that had been reported by several mainstream press sources and which was initially broadcast by some industry groups, prompting some confusion.
This Stroock Special Bulletin provides a very brief overview of the most recent developments.