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The New Fiduciary Regs: A Practical Review, Part 3 (PDF)
Ferenczy Benefits Law Center LLP 
[Guidance Overview] Sept. 2, 2016
"[The authors have seen] a continuous fluctuation in the level of practitioner or pundit confidence that they have correctly interpreted certain sections of the regulation or the prohibited transaction exemptions. Points that we all thought were clear on first or second glance through the rules don't seem so understandable on our third or fourth look. What one practitioner questions is different from what another sees as problematic. And, the more discussions we have with others in the industry, the more unclear much of the regulation appears. Here is a selection of the material unanswered questions[.]"
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