ROBERT R. GOWER, December 7, 2017 On November 29, 2017, the Department of Labor (the DOL) released a final rule (the “final rule”) extending the transition period for compliance with certain requirements of the Conflict of Interest Rulemaking package (commonly known as the “Fiduciary Rule”) by 18 months to July 1, 2019.1 While certain requirements […]
Robert Gower
NICHOLAS WHITE, ROBERT GOWER and ADRINE ADJEMIAN, May 2017 Following months of uncertainty stemming from a February 3, 2017, Presidential memorandum ordering the Secretary of Labor to conduct a review of the final fiduciary advice regulatory package (the “Final Rule”), including a 60-day delay in its applicability date, it seems all but certain the […]
ROBERT R. GOWER, March 2017 On Friday, March 10, 2017, the Department of Labor (“DOL”) published on its website Field Assistance Bulletin 2017-01 (“the FAB”) providing a temporary enforcement policy for the DOL’s Fiduciary Rule and related Best Interest Contract Exemption (“BICE”). The Fiduciary Rule and BICE, which have become the subject of reevaluation […]
ROBERT R. GOWER, February 2017 On Friday, February 3, 2017, President Trump signed an executive order calling for the United States Department of Labor (“DOL”) to review the DOL Fiduciary Rule (the “Rule”), which is scheduled (by its terms) to become applicable on April 10, 2017. The implications of the request for review may […]
ROBERT R. GOWER, July 2016 Sponsors of calendar-year qualified plans working to complete the 2015 Form 5500 (Annual Return / Report of Employee Benefit Plan) by the extended filing deadline of October 15, 2016 may have noticed a handful of revisions to the Form 5500 for the 2015 plan year. These “compliance-focused” revisions indicate areas […]
ROBERT R. GOWER, January 2016 – On January 4, 2016, an order issued by U.S. District Judge Phyllis J. Hamilton in Schuett v. FedEx Corp., (No. 15-CV-0189-PJH, 2016 WL 104267 (N.D. Cal. Jan. 4, 2016)) brought light to a long anticipated question surrounding the retroactive application of the United States Supreme Court opinion in United […]
ROBERT R. GOWER and ERIC J. SCHILLINGER, January 2016 — On December 9, 2015, the Internal Revenue Service (“IRS”) issued Notice 2015-86, providing guidance on the application of the June 26, 2015 United States Supreme Court decision in Obergefell v. Hodges (“Obergefell”) to qualified retirement plans under Internal Revenue Code (“Code”) section 401(a) and health […]
ROBERT R. GOWER, July 2015 — On July 21, 2015, the Internal Revenue Service (“IRS”) released Announcement 2015-19, announcing a significant curtailment of the IRS determination letter program for individually designed retirement plans. Announcement 2015-19 eliminates the five-year remedial amendment cycle for individually designed retirement plans and restricts the IRS determination letter program to limited […]
ROBERT R. GOWER, May 2015 — After years back at the drawing board following the withdrawal of proposed fiduciary regulations issued in 2010, on April 20, 2015, the United States Department of Labor (“DOL”) issued a new proposed rulemaking package that more broadly defines the circumstances in which a person who provides “investment advice” may […]
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