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DOL Proposed Regs Expand Definition of Fiduciary
McDonald Hopkins 
[Guidance Overview] Apr. 28, 2015 "Does There Need to be a Written Agreement to Act as a Fiduciary? No ... the proposed regulations will cover any person who renders advice pursuant to a verbal agreement or understanding that the advice being given is directed to the person or plan for consideration in making investment decisions. There are very little formalities necessary to make one a fiduciary.... [F]iduciaries may receive 'reasonable' compensation for services provided; but the compensation must be reasonable. We do not have specific guidance on what is reasonable." |
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