WTF? Why are You Such a Fiduciary?
BULLETIN: The Department of Labor (DOL) Fiduciary Rule
Spotlight On Talent: Scott Brown, Senior Consultant at Compliance Risk Concepts
The Department of Labor (DOL) Fiduciary Rule, was originally scheduled to be phased in over the period encompassing April 10, 2017 – January 1, 2018, but is now to be phased in starting June 9, 2017 including a transition period for the applicability of certain exemptions to the rule extending through Jan. 1, 2018.
In his compliance bulletin WTF? Why are You Such A Fiduciary?, Scott Brown discusses who is defined as a fiduciary, the sort of investments the rule impacts and best practices during the transition period (June 9, 2017 to January 1, 2018).
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Prior to joining Compliance Risk Concepts, Mr. Brown was employed as a Principal Examiner at FINRA from 2005 to 2016. Mr. Brown’s responsibilities at FINRA included sales practice and financial examinations of member firms. Sales practice examinations entailed detailed reviews of member firms’ systems of supervision and control, reviews of policies governing marketing and sales of financial products and services (equities, mutual funds, corporate and municipal debt), and detailed reviews of broker-dealers’ anti-money laundering compliance programs. Financial Examinations involved verification of the accuracy of General Ledgers, Trial Balances, Income Statements, Balance Sheets, Net Capital Computations and FOCUS Filings for a diverse universe of broker-dealers.