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This checklist includes points discussed in the DOL Fiduciary Exemption (2020-02) related to rollovers and in SEC staff bulletins related to the standard of conduct for investment advisers.
The IAA supported the proposed safe harbor for the use of electronic disclosure, particularly the “notice and access” approach, and encouraged the Department of Labor to apply the safe harbor to documents furnished upon request and allow for consolidated delivery of documents.
The IAA responded to a Department of Labor proposal to amend the QPAM Exemption. While we support the DOL’s efforts to protect the interests of Plans and Plan participants, we are concerned that the potential impacts of the proposal would extend beyond these objectives and would have negative consequences that may not be in the best interest of Plans and their participants.
The IAA and other trade associations urge the DOL to extend the comment period for a proposal that would significantly narrow the availability of the QPAM Exemption.
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