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Drinker Biddle and Reath Attorneys Comment Letter to DOL on Proposed Fee Disclosure Guide (PDF)
Drinker Biddle
[Opinion] June 13, 2014
"We respectfully request further clarification on the following seven specific aspects of the rule: [1] Objective parameters for defining multiple or lengthy documents; [2] Objective parameters for defining a sufficiently specific locator; [3] The relationship between the Guide requirement and the change notices mandated under the 408b-2 regulation; [4] Whether the Guide requirement will apply only prospectively or also retroactively following the amendment's effective date; [5] Availability of relief for inadvertent errors or omissions within the Guide; [6] Clarification as to the requirement that the Guide be provided as a separate document; and [7] Clarification of the requirement to 'furnish' the Guide and 'disclose' changes to the Guide."
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