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The New Fiduciary Regs: A Practical Review, Part I (PDF)
Ferenczy Benefits Law Center LLP 
[Guidance Overview] Apr. 19, 2016
"The new Regulation Package ... does not attempt to redefine who is a fiduciary.... [If] you give advice and get paid for it, you are a fiduciary. What the Regulation does do is to clarify what constitutes 'fiduciary advice.' The DOL then endeavors ... to provide fiduciary advisors with a structure under which they may be paid in a 'customary' manner -- i.e., flat fees and certain variable fees.... Step 1: Are you giving advice? ... Step 2: Are you a fiduciary vis-á-vis that advice? ... Step 3: I'm a big shot fiduciary, too, exception ... Step 4: Okay, I'm a fiduciary. So what?"
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