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DOL Proposed Regulation on 408(b)(2) 'Guide' -- Impact on Service Providers
Drinker Biddle Link to more items from this source
[Guidance Overview]
Mar. 20, 2014

"The DOL has requested comments on the appropriate length of the document, and the regulation will be amended to insert a specific number of pages.... [S]ome TPAs may be disclosing their indirect compensation payments from insurance companies and mutual fund complexes through a separate document ... In that case, the TPA would be using multiple documents and would need to either develop a guide or consolidate the disclosures into a single document.... [M]ost recordkeepers will need to develop a 408(b)(2) disclosure guide.... Broker-dealers will probably bear the greatest burden of compliance with the guide requirement, if it becomes final in its proposed form."

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