Secretary of Labor Peretz, in a letter sent to a group of Democratic senators, said that DOL has extended the public comment period for its conflicted advice rules package 15 days, to July 21. In addition, he said a public hearing on the package will be held the week of August 10, after which DOL will re-open the public comment period for an additional 30 to 45 days. 

Summer Plans?
For those of you with nothing better to do, you now have additional time to spend in the office writing comments and to make your reservations for the public hearing in August. Going to the beach is a nice option too.

The Conflicted Advice Rule in a Nutshell
As has been well publicized and reported, the DOL package consists of revised rules, a new prohibited transaction exemption, and amendments to several existing exemptions. In some ways the DOL proposal leaves existing structures in place --- the sale of of participant directed account investment platforms is one example. In others, the sale of variable compensation investment products to plan participants taking distributions and to IRA owners, the DOL proposal is likely to significantly change existing service models. 

Finalization - The Smart Money Prediction
The smart money right now is on DOL getting the package finalized in something like its current form with some adjustments. But as Yogi Berra once said, commenting on baseball (I think),  "It ain't over till it's over."

Enjoy the summer whether you are writing comments to DOL or not!

Every plan sponsor should ask this question.  
The good thing is that there is no one right answer. Your response depends on who you are and what you have --- your facts and your circumstances. 

First, what are PACs and PICs? A PAC is my shorthand for a plan administration committee. Similarly, a PIC refers to a plan investment committee. 

Why have a PAC or a PIC?
Why establish a PAC or a PIC? There are at least two good reasons. Committees are an excellent way to establish accountability and control over important plan processes. They can also be effective way of spreading around plan work to folks with the skills  and ability to handle that work. 

But PACs and PICs are not for everyone.
Small employers such as sole proprietors may not have the person power or tolerance for the formalities of a committee structure. They’re likely to want something a bit simpler, such as calendars and checklists.
Larger employers may find the PAC and PIC structure quite valuable for the aforementioned reasons. Some will opt for both a PAC and PIC. Others may reason that a PAC is all they need or can stand and wrap investment oversight/management responsibilities into the one committee.

What structure you decide on should be the one that best helps you protect your interests and the interests of your employees.

If you are a plan sponsor, have a conversation with your adviser and discuss with them what is best for you.  If you are an adviser, make the question an item of discussion with your clients.