"DOL Shutters Concerns on Brokerage Windows: Paneful Effects Avoided (For Now)"

On July 30, 2012 the Department of Labor ("DOL") provided much needed clarification on a question and answer ("Q&A 30") that recently raised significant controversy.  Q&A 30, issued as part of Field Advice Bulletin 2012-12 was originally released in May of this year in connection with certain final regulations ("Final Regulations") applicable to participant-directed retirement plans governed by the Employee Retirement Income Security Act of 1974, as amended.

This Stroock Special Bulletin discusses DOL's July 30th release, which deletes Q&A 30 and adds a new Q&A-39.