"[It's] too early to say that the Rule is dead. I believe that the SEC will be providing additional and, in some cases, enhanced standards and requiring better disclosures. So, while the particulars of the DOL Rule may have been killed by the 5th Circuit decision, I don't know that the principles are necessarily dead. I think that the SEC will include some of those principles in their guidance. That could include, for example, better disclosures and higher standards of care. In any event, there will be a need for updated prohibited transaction exemptions since the 5th Circuit ruling also vacated the exemptions[.]"

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