Top of Mind

Another Comment Period on the Fiduciary Rule

On June 29th, while you were no doubt busy preparing for the Fourth of July holiday, the Department of Labor (DOL) decided it would be a good time to issue yet another request for comment on the fiduciary rule.  Releasing items on a Friday, or just in advance of a holiday weekend, has been a common strategy in the past for the IRS and the DOL, likely in the hope that these items will receive less notice from the public.

In their excellent summary of the new request for information, Groom Law provides this rather bleak assessment:

“….this RFI is only a single step in a potentially months or years long process aimed toward revising the Fiduciary Rule in accordance with the Presidential Memorandum on the Fiduciary Rule, 82 Fed. Reg. 9675 (Feb. 3, 2017) (the “Memorandum”), directing DOL to study the Fiduciary Rule, and, if warranted, to rescind or revise it."

The boldface text is my emphasis - and I, for one, am not thrilled.  Years?  Seriously?

It has already been eight long years since the investment advice rule, the predecessor to the final fiduciary rule, was first proposed.  In the intervening time, there have been proposed rules, final rules, and too many comment periods and public hearings to count. To be frank, while I know others will disagree, I believe we have waited long enough for a rule that is final, effective, and applicable. Hopefully we will have one before I retire!

Do you agree with me?  Or were you actually looking forward to another comment period?  Feel free to let me know your thoughts by messaging me on Twitter or emailing me at  

Note: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.

Investment products available through Cammack LaRhette Brokerage, Inc.
Investment advisory services available through Cammack LaRhette Advisors, LLC.
Both located at 100 William Street, Suite 215, Wellesley, MA 02481 | p 781-237-2291