ADISA Submits Comment Letter in Support of the DOL's Proposal to Extend Fiduciary Rule

Sep 11, 2017

Under the recently published proposal, the transition period would extend until July 1, 2019
ADISA submitted a comment letter to the Department of Labor’s Office of Exemption Determination, EBSA, regarding its recent proposal to delay for 18 months the special transition period for the Prohibited Transaction Exemptions of its fiduciary rule. As proposed, the delay would be in effect until July 1, 2019. Currently, the special transition period for exemptions 2016-1, 2016-2 and 84-24 are set to expire on January 1, 2018.
ADISA is pleased to go on record as supporting the proposed extension of the special transition periods currently applicable to the Exemptions. The proposed delay will, if adopted, provide the Department with time to consider these issues in a thoughtful way and to obtain commentary and analysis from the financial services industry and to coordinate with other agencies and interested parties in connection with that process.
“ADISA is pleased to support the Department’s latest attempt to gain additional time to study and, where appropriate, remedy aspects of the Fiduciary Rule and the accompanying exemptions as originally adopted,” said ADISA President John Grady of DLA Piper. “We continue to oppose regulation that, however well intended, does not help investors or their advisers, and we trust that, with time, additional study and the input of other agencies, the Department will be better able strike a balance that helps retirement savers get the products and services they need to meet their goals while not undermining their ability to access financial professionals to serve them.”

ADISA has previously provided commentary to the Department both in letters and in person on aspects of the Fiduciary Rule. ADISA representatives have also appeared before the Office of Management and Budget and presented evidence and research as to the immediate problems and potential harmful unintended consequences of the Fiduciary Rule as it has been proposed. (For a full overview of all of ADISA’s Fiduciary Rule advocacy efforts, go to
The letter was authored and signed by President Grady as well; you can view it in its entirety here.