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American Benefits Council Supplemental Comment Letter to EBSA on Conflict of Interest Rule (PDF)
American Benefits Council Link to more items from this source
[Opinion]
Sept. 25, 2015
8 pages. "The definition of fiduciary advice should clarify that casual conversations not involving any expectation of material reliance are not fiduciary advice.... Under the proposal, any 'suggestions' offered 'for consideration' are sufficient to trigger fiduciary status. This is too low a bar and too broadly defined.... We continue to believe that the current rule in Interpretive Bulletin 96-1 should be preserved. We did not see anything in the Department's Regulatory Impact Analysis documenting that there have been any problems under 96-1. If the Department has concerns about the use of examples, a more targeted rule should be considered."

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