Stroock Special Bulletin
"Will Time Derail 'Fiduciary' Delay’s Arrival? DOL FABulously Pledges to 'Mind the Gap' on Enforcement"
On Friday, March 10th, the Department of Labor released guidance concerning its enforcement policy under the "fiduciary" rule scheduled to take effect on April 10th. On March 2nd, the Department asked for comments on a 60-day delay and, separately, the President issued a Memorandum with questions to the Department concerning the rule.
This Stroock Special Bulletin briefly describes the Department's effort to calm market participants' concerns about the tight timeframe and uncertain paths forward, including how the Department "minds the gap" on certain possible enforcement actions that could arise from timing difficulties occasioned by this flurry of events.