Adrine Adjemian

18-Month Delay for Fiduciary Rule’s Transition Period

ADRINE ADJEMIAN, August 2017   On Thursday, August 31, 2017, the Department of Labor (the “DOL”) published a proposed extension of the transition period and applicability date for the fiduciary regulation’s (the “Fiduciary Rule”) best interest contract exemption (the “BICE”) and the principal transaction exemption. The DOL proposed amendment would also extend the applicability date of […]

Fiduciary Rule to Go Live June 9, 2017

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 […]

(Mild) Relief for Safe-Harbor Hardship Administration

ADRINE ADJEMIAN and BENJAMIN F. SPATER, March 2017    Provided that certain notice requirements have been satisfied, employers and third-party administrators (“TPAs”) can now allow participants requesting safe-harbor hardship distributions to provide a summary of information contained in source documents evidencing their hardship event in lieu of the source documents, as long as they maintain […]

The Final Fiduciary Rule: Top Five Takeaways for Plan Sponsors

ADRINE ADJEMIAN, ROBERT R. GOWER and BENJAMIN F. SPATER, April 2016 – On April 8, 2016, the Department of Labor (“DOL”) published the final fiduciary advice regulatory package (the “Package”). The Package includes regulations introducing a dramatically revised definition of who is considered a “fiduciary” by rendering investment advice for a fee (the “Final Rule”), […]

DOL Issues Final Fiduciary Rule

ADRINE ADJEMIAN, April 2016 – On Wednesday, April 6, 2016, the Department of Labor (DOL) issued a pre-publication version of its long-awaited controversial final fiduciary advice regulatory package. The package is scheduled for publication in the Federal Register on April 8, 2016. This rule is the first meaningful update to retirement advice regulations since 1975, […]

DOL’s Newly Announced Investigation into Defined Benefit Plans for Failure to Pay Participants

ADRINE ADJEMIAN, February 2016 On January 22, 2016, during a panel discussion (which included Brad Huss) at the Los Angeles Advanced Pension Conference, Elizabeth Hopkins, Counsel for Appellate and Special Litigation, Office of the Solicitor, Plan Benefits Security Division, United States Department of Labor (“DOL”), stated that the DOL has initiated an investigation into large […]