DOL Fiduciary Rule Delay

CUNA has expressed support for the goal of the Fiduciary rule to protect investors and encourage all advisors to act in the investor's best interest. However, the letter highlights that because of the complexity of this rule and the uncertainty about compliance deadlines and applicability, a delay and additional analysis of the fiduciary rule would benefit credit union members.

A February 3, Presidential memo indicated that there could be changes to the rule.  It was also widely reported that the DOL sent a request to the Office of Management and Budget for a 180-day delay to the rule.  However, the proposed rule only seeks a 60-day delay.

CUNA in its letter notes that many in the credit union industry and financial services industry were relying on at least a 180-day delay for compliance. We urged the DOL to institute a 180-day delay to allow time for the credit union industry to understand any changes that are made to the rule, and allow additional time to understand any compliance and applicability complexities associated with the rule.

CUNA in its letter thanks the DOL for including some of our requested clarifications from the proposed rule stage, in the final rule including some explanations about what is financial education v. advice. We believe these clarifications make clear that credit unions can continue to have broad conversations with their members about financial education, and have the ability to provide general information about opportunities to invest and save. However, the letter outlines three situations in which credit unions could still be impacted by this rule.

CUNA Comment Letter 03/16/2017
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Leah Dempsey