"Quoth the DOL, ‘Nevermore’?"

Delays Fiduciary Rule Until June – But Isn’t Raven About Future Action

On April 4, 2017, the Federal Register posted a notice of delay of 60 days by the U.S. Department of Labor of the first scheduled applicability date for the so-called investment advice “fiduciary” (or conflict of interest) rule under the Employee Retirement Income Security Act of 1974, as amended, originally scheduled for April 10, 2017.  

This Stroock Special Bulletin provides an overview of the notice, which revises the first “applicability date” to now be June 9, 2017.  The January 1, 2018 “applicability date” remains unchanged. 

The Fiduciary Rule would impact many accounts subject to Title I of ERISA and other arrangements subject to similar provisions of the Internal Revenue Code and those financial services companies that deal with them.