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CIEBA Comment Letter to DOL on Improving Investment Advice for Workers and Retirees -- Strengthening Protections for Rollovers (PDF)
Committee on Investment of Employee Benefit Assets [CIEBA] 
[Opinion] July 30, 2020 "CIEBA continues to believe that DOL should re-evaluate the Five Part Test, which was issued well before the proliferation of 401(k) plans. Those who market and recommend rollovers to plan participants should be fiduciaries under ERISA, and the Five Part Test should make it much more clear that rollover providers are almost invariably acting as fiduciaries in the context of the rollover." |
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