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Compliance and Regulatory Alerts  |  08-31-17

OMB Approves DOL Fiduciary Rule Delay


On August 28, 2017, the Office of Management and Budget approved the Department of Labor’s (DOL) 18-month Fiduciary Duty Rule (Rule) delay request, extending the Transition Period and applicability of certain requirements and exemptions of the Rule until July 1, 2019. As of the writing of this note, the DOL announced that they will file a 15-day comment period, set to appear in the Federal Register in coming days, giving the DOL time to draft and submit for comment a more streamlined version of various components of the Rule and exemptions.

Most notably, the delay in the applicability date of the additional Rule requirements includes the class action provision of the Best Interest Contract Exemption. Note that this extension does not relieve providers of retirement advice any exemption from compliance with the Transition Period requirements, including the Impartial Conduct Standards. Bates Compliance Solutions will keep you posted on continuing developments.

If you should have any questions or need assistance managing your DOL Fiduciary Duty Rule strategy and implementation, please contact Michael Bernardo, Managing Director of Bates Compliance Solutions, at 732-904-1548 or


About BCS

Bates Compliance Solutions (BCS) is composed of experienced former regulators and compliance professionals, including CAMS-certified experts, who provide world‐class Compliance and Regulatory services and support for new and existing Broker-Dealer, Registered Investment Adviser (RIA) and hybrid firms at prices that are more than competitive. BCS offers custom-tailored front office, governance, compliance, risk, and audit solutions, including DOL Fiduciary Duty Rule strategy, on a case-by-case basis or as continuous, ongoing advice and support.