DOL Fiduciary: Joint Trades Extension Request

The undersigned associations request an extension of the 60-day comment period for the Department of Labor’s (DOL) Proposed Retirement Security Rule and considerable amendments to a number of Prohibited Transaction Exemptions (Proposed Rule). The Proposed Rule makes significant and unanticipated changes to the current regulatory framework that will require significantly more time for meaningful analysis and comment, and to understand how this proposal would impact access and choice for retirement savers.

This brief of a comment period for a proposed rule on the definition of a fiduciary, is unprecedented. When the 2010 Fiduciary Rule was released, DOL initially had a 90-day comment period, followed by a 14-day extension. DOL then held a public meeting, followed by a 15-day comment period for response. For the 2016 Fiduciary Rule and Related Exemptions, DOL allowed a 75-day comment period and granted a 15-day extension. After a public hearing, there was then another 15-day comment period. We believe that DOL should again provide at least a similar comment period, especially for a proposal that is nearly 500 pages long.