"Given the retail customer and investor definitions, recommendations to the following are out of scope for both the Regulation BI and Form CRS requirements: [1] Institutions, including providers of retirement plans and accounts. [2] Plan sponsors or other plan fiduciaries, at least with respect to plan-level investment matters unrelated to the retirement savings of specific individuals.... Consistent with the [DOL's] longstanding position under [ERISA], the final rules also make it clear that 'investment education' -- as long as it does not become transaction-specific -- is not a recommendation in the scope of Regulation BI."  MORE >>