Nicholas Pension Consultants
Compensation Strategies Group, Ltd.
Nova 401(k) Associates
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|Coalition Letter to Congress on DOL's Proposed Rulemaking Expanding Fiduciary Investment Advice Under ERISA (PDF)|
Approximately 500 Trade Associations, Chambers of Commerce, Employer Organizations, and Small Businesses
Sept. 29, 2015
18 pages. "Because an advisor to a small plan is not carved out of the rule, the advisor who is trying to market retirement saving options to a small plan is considered to be providing investment advice and must determine how to comply with the rule. Advisors to large plans are not burdened with these additional hurdles.... [T]he new exemption proposed by the DOL may not apply to small business plans.... Even if the new exemption -- called the 'Best Interest Contract Exemption' -- does apply, it would itself substantially increase costs for advisors due to its many conditions and requirements.... [T]he DOL's proposed regulations risk hurting the very small businesses and workers they are intended to protect."
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