If your Policies and Procedures Manual says you do ‘X’ then you should be doing it. In the past year I have added a policy for the DOL Rule to client Policies and Procedures Manuals. Examiners have been asking about those policies and what the firms have done to meet the requirements of those policies.
Many people believe the that DOL Rule is dead. The 5th Circuit has not vacated the Rule, so it is still in effect. What has become clear during the SEC examinations is that the examiners are using the Policies and Procedures Manual to determine if firms are meeting their DOL Rule requirements.
Be sure that you are doing what your Manual says you are doing, especially regarding the DOL Rule.
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