In determining whether someone under the new fiduciary regulation is providing educational assistance to a plan participant or giving actual advice, when the investment professional is actually assisting that participant with completing a risk tolerance profile questionnaire/assessment-would that constitute advice since they are discussing the individual's personal situation...or NOT because it is the participant actually providing the answers and the investment professional is just there in case they had a question about how to complete the form? Where is this line. I've read a lot of articles, but it seems this is a pretty thin line...When do they become a 3(21) fiduciary or get to remain under a suitability standard?