“It would seem that the retirement industry can hardly avoid planning and proceeding in a manner that would prepare them for eventual compliance.”
- A firm acknowledges fiduciary status for itself and its advisers.
- Basic standards of impartial conduct must be adhered to in giving advice.
- Compensation must be reasonable (not fully defined in the final guidance).
- Procedures and policies must be in place to mitigate investor harm due to conflicts of interest.
- Both potential conflicts and compensation arrangements must be disclosed.
- The Employee Benefits Security Administration must be notified by email if a BIC is being used in an advising relationship.
