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DOL Redefines an ERISA 'Fiduciary' (PDF)
Chao & Company, Ltd. Link to more items from this source
[Guidance Overview]
Apr. 11, 2016
9 pages. "As a general theme, the exemptions differentiated a recommendation from general communication where a recommendation is deemed to be investment advice and subjects the advisor to be a fiduciary. Responsibilities are placed on the advisers intending to use an exemption to know or reasonably believe that the counterparty is a fiduciary.... An investment platform (which is often affiliated with or a part of recordkeeping services and asset managers) can avoid being considered offering recommendations if the communication is not individualized and clearly discloses in writing that the platform is not a fiduciary and should not be deemed as offering impartial investment advice."

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