NAPA Net - Polling Places 072922

Are Your Rollover Recommendations “Ready?”

As you all (hopefully) know, there are some new rules regarding rollover recommendations – notably the requirement to document – in writing – why a rollover is in the participant’s best interest. This week - if you work with rollovers – or if you’re thinking about it – we’d like to know what you think.

That’s right, the Labor Department’s expanded definition of fiduciary advice is described in the preamble to PTE 2020-02. The PTE then provides relief for conflicted non-discretionary recommendations (for example, rollover recommendations), if its conditions are satisfied.

Question Title

1. Do you "do" participant rollovers?

Yes.

No.

I used to, but not any more.

Not yet.

care to expand on that?

Question Title

2. Do others at your firm "do" participant rollovers?

Yes.

Not yet.

No.

We used to, but not any more.

care to expand on that?

Question Title

3. If you/your firm "do" rollovers, have you started documenting in writing the best interest justification for doing so?

Yes, and prior to July 1.

Not yet.

I/we don't "do" rollovers.

Yes. since July 1.

Other thoughts?

Question Title

4. If you/your firm "do" rollovers - how have you found the written documentation requirement (check all that apply)?

Helpful

Painful

Instructive.

Useless.

Unnecessary.

Powerful.

Something else?

Question Title

5. Other comments about rollovers, doing rollovers, not doing rollovers, deciding to do - or not do - rollovers, documenting the best interests for a rollover, not documenting the best interests for a rollover, knowing that some don't know you had to document the best reasons for a rollover, or life in general?

Question Title

6. What is your role working with retirement plans?

Advisor

Provider

TPA

Plan sponsor

Recordkeeper

Other (please specify)

Question Title

7. What size plans do you PRIMARILY work with?

Under $10 million in assets

$10-$20 million

$20-$50 million

$50-100 million

$100 million - $250 million

$250 million - $500 million

Above $500 million

Other (please specify)

Question Title

8. Suggestions for future survey questions?

Question Title

9. All responses are anonymous and confidential, of course - but if you'd like me to know who you are, or allow for a response, you can leave your email below...

Question Title

* 1. Do you "do" participant rollovers?

Question Title

* 2. Do others at your firm "do" participant rollovers?

Question Title

* 3. If you/your firm "do" rollovers, have you started documenting in writing the best interest justification for doing so?

Question Title

* 4. If you/your firm "do" rollovers - how have you found the written documentation requirement (check all that apply)?

Question Title

Question Title

* 6. What is your role working with retirement plans?

Question Title

* 7. What size plans do you PRIMARILY work with?

Question Title

* 8. Suggestions for future survey questions?

Question Title

* 9. All responses are anonymous and confidential, of course - but if you'd like me to know who you are, or allow for a response, you can leave your email below...

1. Do you "do" participant rollovers?

2. Do others at your firm "do" participant rollovers?

3. If you/your firm "do" rollovers, have you started documenting in writing the best interest justification for doing so?

4. If you/your firm "do" rollovers - how have you found the written documentation requirement (check all that apply)?

6. What is your role working with retirement plans?

7. What size plans do you PRIMARILY work with?

8. Suggestions for future survey questions?

9. All responses are anonymous and confidential, of course - but if you'd like me to know who you are, or allow for a response, you can leave your email below...