See Credit Details Below
Overview
On April 23rd, 2024, the Department of Labor released its much anticipated “Retirement Security Rule: Definition of an Investment Advice Fiduciary” (the “Final Rule”) redefining who is a fiduciary by virtue of providing investment advice with respect to “plan assets” subject to ERISA and/or Section 4975 of the Code. The DOL also finalized amendments to certain Prohibited Transaction Class Exemptions (“PTEs Amendments”), including PTE 2020-02. The Final Rule will become effective on September 23, 2024. The amendments to the PTEs will also largely take effect on that same day (with a one-year phase-in period for certain requirements). Before the effective date, plans and service providers will need to consider the impact of the Final Rule and PTE Amendments and determine if changes are necessary in light of the new rules.
Specific issues to be addressed include:
- The path from 1975 to 2024 (10 minutes)
- Description of Final Rule (including the differences between the Final Rule, the Current Rule and the proposed rule) (30 minutes)
- Discussion of the potential impact of the Final Rule (20 minutes)
Who Should Attend: Outside attorneys, in-house counsel, plan counsel, compliance, finance, and other professionals interested in learning more about the DOL’s New Fiduciary Rule and the related amendments to certain Prohibited Transaction Class Exemptions.
Program Level: Update
Prerequisites: None
Advanced Preparation: None
Faculty:
Elizabeth L. Dyer
Cleary Gottlieb Steen and Hamilton LLP
Timothy D. Hauser
U.S. Department of Labor
Linda J. Haynes
Seyfarth Shaw LLP