PTE 2020-02 Mistakes and Misunderstandings, Part 4: Navigating Compliance Challenges

Faegre Drinker

Please join us for this series focused on the U.S. Department of Labor’s (DOL) Prohibited Transaction Exemption 2020-02 and potential pitfalls of the exemption. The series will focus on what may be misunderstood about the exemption. 

The U.S. Department of Labor expanded its interpretation of the ERISA and Code regulatory definitions of non-discretionary fiduciary investment advice and provided PTE 2020-02 —  an exemption, or exception, to the prohibitions on conflicts of interest. With all conditions of PTE 2020-02 now fully in effect, financial institutions are encountering challenges to compliance. Please join us for the fourth webinar in this series where Faegre Drinker attorneys will examine and address these issues, including:

• When do “hire me discussions” become fiduciary advice?
• Recommending a change in account types for an IRA – when does the PTE apply?
• Recommending an IRA rollover from an ERISA plan that results in no additional compensation —  even though there is no conflict of interest, a best interest process is still needed to satisfy the ERISA standard of conduct and all that entails.
• Mitigating conflicts of interest – compliance considerations.
• PTE failures and challenges with implementing the self-correction process.

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