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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 BusinessesLink to more items from this source
[Opinion]
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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