Wealth Management

(New York)

Rollovers are one of the most important and hotly contested areas of forthcoming regulation. The mostly defunct DOL rule stated that advisors need to act in the best interest of clients when dealing with rollovers only if the firm was a fiduciary. However, the big forthcoming change is that the SEC Best Interest rule essentially states that advisors AND brokers need to act in the best interest of clients all the time, but allows that disclosure of material conflicts can be sufficient to overcome any hurdles. According to Drinker Biddle & Reath, a leading wealth management law firm, “Reg BI standard of care obligation requires that a broker-dealer have a reasonable basis to believe that taking the assets out of the plan and rolling them over to an IRA is in the best interest of the participant at the time of the recommendation”.


FINSUM: So the DOL rule was very strict but fairly narrow in application, while the SEC rule is broader (encompassing brokers and fiduciaries) but less strict.

(Washington)

In what comes as a surprise, the new iteration of the DOL rule may in fact be multiple rules bundled into a package. A lawyer from well-respected industry law firm Drinker Biddle & Reath says they have credible rumors that there will be multiple new rules, and that they will be friendly for those in the industry. The firm says that the new rules will likely be based on the old 1975 five-part test, and that the Best Interest Contract Exemption will be replaced. The new DOL package is also supposed to harmonize well with the SEC’s new Best Interest rule, which was approved in June.


FINSUM: It is good news that this rule is supposed to be more friendly to those in the industry, but it is worrying that there may be multiple rules. The more components there are to the rule, the more likely it will be that it is unclear.

(New York)

Is it a huge deal or not? No one seems to be able to decide. The issue at hand is that the new SEC Best Interest rule explicitly requires brokers to consider costs when recommending products to clients. That is potentially a very big change. However, some say brokers have already been doing this as part of suitability rules, so it may not change practices much. It is important to note that brokers do not need to recommend the cheapest product to clients, but they must take cost into consideration.


FINSUM: Considered in a vacuum, taking cost into consideration has long been a no-brainer. The bigger question is how the SEC decides to enforce this standard. Hindsight will always be 20-20 in an investigation and this could be a big disadvantage to brokers.

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