Jason C. Roberts
Chief Executive Officer PENSION RESOURCES INSTITUTE, LLC
Overland Park, Kansas

As it turned out, rumors of the 11th-hour, Trump-era DOL fiduciary rule’s death were greatly exaggerated.  On December 20, 2021, the DOL’s “temporary enforcement policy” expires and financial institutions will need to comply with the technical conditions of prohibited transaction exemption 2020-02 any time their representatives provide “investment advice” concerning rollovers from qualified plans or IRAs.  Bank trust departments and RIAs will, at a minimum, need to update contracts, disclosures, policies and procedures and representative and supervisor training, as they are in the business of providing investment advice on a “regular basis” to tax-advantaged retirement accounts. Because these institutions are not expressly subject to the SEC’s Regulation Best Interest, they may not have a sufficient foundation in place today from which to incorporate the new requirements.  Even broker-dealers that are governed by Reg. BI will need to make changes given the nuances between the two.

Jason C. Roberts, CEO of Pension Resource Institute and Retirement Law Group will describe how the new requirements impact financial institutions – particularly banks – as well as the DOL’s enforcement regime and penalties for non-compliance.  He will share his first-hand experiences as a former litigator defending financial institutions and from helping those firms prepare to implement, maintain and test the new required policies and deliver to attendees an actionable plan for meeting the pending deadline.