On April 8, 2016 the Department of Labor published controversial final rules significantly expanding the definition of a fiduciary with respect retirement plan accounts for the purposes of ERISA and Section 4975 of the Internal Revenue Code. These rules will have far-reaching implications for the financial services industry and will require substantial changes in many firms’ business models as they relate to IRAs and other retirement plans. 

The following visual memo explains the new rules and describes how the financial services industry will be impacted, particularly with respect to broker dealers who offer platforms to IRAs, structured products issuers, mutual funds sponsors, private investment fund sponsors, defined benefit pension plan service providers and insurance and annuity product issuers.

If you have any questions regarding the matters covered in this publication, please reach out to any of the lawyers listed below or your usual Davis Polk contact.

This communication, which we believe may be of interest to our clients and friends of the firm, is for general information only. It is not a full analysis of the matters presented and should not be relied upon as legal advice. This may be considered attorney advertising in some jurisdictions. Please refer to the firm's privacy notice for further details.

Related materials

Read the full update
Copy link to share post