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DOL's Fiduciary Reg: Recent Developments (PDF)
Ferenczy Benefits Law Center LLP 
[Guidance Overview] Jan. 25, 2017
"[F]or the TPAs: Neither the original regulations nor the first set of FAQs addressed what we considered to be the most important question for you: is the recommendation of a financial institution to act as recordkeeper and fund holder a fiduciary recommendation under the new rules? ... [T]he second set of FAQs revealed that the answer to this question is a definitive 'no,' so long as you are not giving advice about the actual investments.... The second set of FAQs clarified that ... [if] there is no prohibited transaction, there is no need for an exemption, including BICE. This means that the business model of advisors using the offset model for compensation will likely be able to continue unchanged."
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