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The DOL's 2016 Final Fiduciary and Conflict of Interest Regs: The Principal Transactions Exemption
Mintz Levin [Guidance Overview] June 13, 2016 "Riskless principal transactions are the functional equivalent of agency transactions. As such, they are also covered under the Best Interest Contract exemption. This means that riskless principal transactions can proceed under either exemption, thereby resulting in 'some overlap between the Best Interest Contract exemption and the principal transaction exemption.' The Best Interest Contract exemption, however, provides broader relief for all recommended purchases." |
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