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TIAA Comment Letter to DOL on Examination of the Final Fiduciary Rule (PDF)
TIAA 
[Opinion] Apr. 19, 2017
16 pages. "Recommendations concerning subsequent investment or use of Required Minimum Distributions (RMD) payments should not be fiduciary advice.... The education exclusion should be expanded to include a service provider's recommendations about enrolling in or contributing to a plan ... The definition of 'Best Interest' should mirror ERISA's 'prudent man standard of care' under ERISA Section 404(a) for all retirement investors.... The BIC Exemption should be expanded to accommodate advice to participants of the advice provider's own employer sponsored plans."
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