The first phase of the Department of Labor’s (“DOL”) new fiduciary rule (“Fiduciary Rule”) was scheduled to be implemented on June 9, 2017. The Fiduciary Rule greatly expands the categories of persons who are deemed fiduciaries when dealing with retail retirement investors. It was adopted by the DOL in April 2016 together with new prohibited transaction exemptions: the Best Interest Contract Exemption (“BIC Exemption”) and the Principal Transactions Exemption (“Principal Transactions Exemption”).

For more guidance relating to the DOL’s new fiduciary rule, please see our resources below:

Morrison & Foerster Seminar: Department of Labor Fiduciary Rule (March 8, 2017)

Blog Post: IM Insights : DOL Proposes to Defer Full Implementation of its Fiduciary Rule Until July 1, 2019 (September 1, 2017)
Blog Post: IM Insights: Does a Proposal for Further Delay in Implementation of the DOL Fiduciary Rule Suggest Major Changes Are Coming? (August 14, 2017)
Blog Post: IM Insights: DOL Issues Request for Information Regarding Fiduciary Rule (June 30, 2017)
Blog Post: IM Insights: Implementing the DOL Fiduciary Rule (May 31, 2017)
Client Alert: Living with the DOL Fiduciary Rule: Be Prepared for the June 9 Implementation Date (May 26, 2017)
Client Alert: DOL Fiduciary Rule Delayed by 60 Days (April 5, 2017)
Client Alert: DOL Issues Additional Guidance on Fiduciary Rule (January 23, 2017)
Client Alert: DOL Issues First Guidance on Fiduciary Rule (October 31, 2016)
Newsletter: Structured Thoughts: Special Edition (May 4, 2016)
Client Alert: Final Department of Labor Fiduciary Regulations under ERISA (April 7, 2016)

Implementation of the Department of Labor’s (“DOL”) Fiduciary Rule: A Cheat Sheet
A Timeline of Recent Presidential Actions on Regulation Reduction


For more information, contact:
Hillel Cohn,, (213) 892-5251
Paul Borden,, (415) 268-6747