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Testimony of Norman Stein Before DOL Hearing on Proposed Regulations Defining Fiduciary (PDF)
Pension Rights Center Link to more items from this source
[Opinion]
Mar. 3, 2011
My statement today will cover five points: first, that the current regulations improperly constrict the statutory definition of fiduciary; second, that the current regulations were promulgated in a different economic and legal environment than today and as a result sometimes fail today to shield unsophisticated participants in retirement plans from investment advice tainted by conflicts of interest; third, that the proposed regulations should not condition fiduciary status on whether aperson provides 'individualized' investment advice; fourth, that the 'sales' limitation on the definition of fiduciary status should not apply to advice given to participants; and fifth, that advice about distributions should be considered investment advice.

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