Being a Good Fiduciary is About a Documented Process

The Importance of Documentation of the Rollover Evaluation

Prohibited Transaction Exemption 2020-02 has re-written the rules for recommending rollovers. The SEC has also
entered the fray with Reg BI, the Investment Adviser Interpretation and, more recently, its Staff Bulletin about
account recommendations.

The DOL and SEC expectations have largely merged. For a rollover recommendation to be made, both the SEC and
the DOL agree that the steps are:

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