annuity

After all the dust from the last-minute legal wrangling settled, the ruling by the 5th Circuit Federal Court of Appeals vacating the Department of Labor Fiduciary Rule (the Rule) finally took effect on May 7th, 2018. The Rule, and all of its associated prohibited transactions, including the Transition Best Interest Contract Exemption, are removed from the list of Federal regulations and no longer apply.  | more

We are pleased to inform you the Fifth Circuit Court of Appeals decided to vacate the Department of Labor’s Fiduciary Rule. A number of procedural matters must still occur before the decision is final. The Department of Justice has 45 days to request a rehearing by the Fifth Circuit. If a rehearing is not requested or is denied, the Fifth Circuit will issue a mandate in early May making its decision fully effective. The Department of Justice also has 90 days to appeal the decision to the Supreme Court. Until this all gets sorted out, please continue to use PTE 84-24 disclosure paperwork for your life and annuity transactions involving qualified money.
Sample PTE 84-24 Disclosure

The Department of Labor (DOL) recently announced that the more onerous provisions of the Fiduciary Rule, originally scheduled to take effect January 1, 2018, have been delayed until June 30, 2019. The delay does not “roll back” any elements of the existing regulation. As a result, policies and procedures that were instituted in June of this year remain necessary, and in effect. Over the coming months, we expect that the DOL will continue to study whether the rule will have a negative impact on the retirement security of main street Americans, and whether the rule should undergo further changes. Until then, please continue to use PTE 84-24 disclosure paperwork for your life and annuity transactions involving qualified money.
Sample PTE 84-24 Disclosure

The Office of Management and Budget (OMB) recently approved an 18-month delay for the more onerous provisions of the Department of Labor (DOL) Fiduciary Rule. The DOL proposed amendments to three exemptions, which were all approved by OMB. The delay covers the best-interest contract exemption, Prohibited Transaction Exemption 84-24 (PTE 84-24) and class exemption for principal transactions in certain assets between investment advice fiduciaries and employee benefit plans and IRAs. While we are still waiting for guidance as how to best proceed, nothing happens until the DOL finalizes the delay. We are expecting this in the coming weeks. Until then, please continue to use PTE 84-24 disclosure paperwork for your life and annuity transactions involving qualified money.
Sample PTE 84-24 Disclosure