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.

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* 1. Do you "do" participant rollovers?

I used to, but not any more.

No.

Yes.

Not yet.

care to expand on that?

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

No.

We used to, but not any more.

Yes.

Not yet.

care to expand on that?

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

I/we don't "do" rollovers.

Yes. since July 1.

Yes, and prior to July 1.

Not yet.

Other thoughts?

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* 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?

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* 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?

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

Advisor

Provider

TPA

Plan sponsor

Recordkeeper

Other (please specify)

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* 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)

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* 8. Suggestions for future survey questions?

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* 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...