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The DOL's Fiduciary Proposal 3.0: Exemption and Investment Advice Fiduciary Definition (PDF)
Eversheds Sutherland
[Guidance Overview] July 8, 2020 21 pages. "[It] now is more widely understood that: [1] There can be no financial services business model that is unconflicted in the absolute sense that ERISA presumes fiduciaries can be; and [2] At least in part, these conflicts arise from the industry's function in our financial system and are shaped by the primary pattern of regulation to which that industry is subject. Because those financial services are indispensable to the operation of the private retirement system, ERISA's share of the regulation of those industries must accommodate to those realities." MORE >> |
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