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!