DOL Fiduciary Duty Rule

The Department of Labor (DOL) Fiduciary Rule (the “Rule”) regulatory package was released on April 6, 2016. The DOL Rule significantly expands the definition of investment advice as it relates to employee benefit plans and individual retirement accounts, expanding the universe of individuals and firms who will be considered fiduciaries subject to the stringent fiduciary standards of ERISA and the Internal Revenue Code. Because a fiduciary is required to act in the “best interest” of the investor, firms have been working to revise their business models to demonstrate that the advice they provide to retirement investors is in investors’ best interest.

The Rule has withstood several legal challenges, a change in administration following the November 2016 presidential election, and a brief delay, becoming applicable on June 9, 2017. Additionally, an 18-month delay on requirements to comply with the remaining provisions in the Rule was approved by Office of Management and Budget on August 29, 2017, extending the applicability date from January 1, 2018 to July 1, 2019.

With ~50% of US retail financial assets in retirement accounts, the Rule has driven significant changes to product, pricing, compensation, compliance regimes, technology and operations practices at US wealth managers, asset managers, retirement platform providers and annuities manufacturers and distributors.

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7 Day Yield - Fate of the DOL Fiduciary Rule, plus impact investing

PwC's Arjun Saxena provides an update on the DOL Fiduciary Rule. Plus, PwC's Don Reed explains why impact investing is on the rise. Dr. Alexis Crow appears as our guest and shares other examples of where we're seeing a rollback in regulations.


How PwC can help

PwC is the industry leader for DOL Fiduciary Rule strategy and implementation and has helped a significant number of financial institutions develop and implement solutions to address their DOL challenges. We have a dedicated DOL practice composed of industry experts that are at the forefront of thought leadership, are familiar with the DOL’s perspective, and monitor how industry participants are developing solutions for the Rule.

Scope of services


  • Robust rule response strategy development
  • In-depth industry knowledge and insights on Rule implementation best practices
  • Dedicated DOL practice and engagement teams with significant expertise in wealth management industry and DOL Rule

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Impact assessment

  • In-depth economic impact analysis, including revenue, cost and money-in-motion impacts
  • Highly efficient baseline analysis and business/operations impact evaluation, including business strategy, products, services, clients, associates, operations and technology

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Best Interest Contract (BIC) Exemption and other exemptions

  • Customized strategic decision making framework
  • Focused executive workshops and working groups for decision making on use of BIC exemption and / or other exemptions
  • Target operating model design for contract delivery, disclosure delivery, dialogue model, supervision model, etc
  • Process optimization that may create synergies and benefit other businesses or processes
  • Business and technical requirements development
  • Effective support throughout the technology roadmap to implement the target operating models and business and technical requirements

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Product rationalization

  • Identification of high risk areas with regard to the Rule context
  • Strategies for new product development and / or new share classes development

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Pricing and compensation

  • Re-evaluation of pricing and compensation strategies and mechanisms to address conflicts of interest
  • Neutral factor framework to address differential compensation
  • Design and implementation of new product pricing, FA compensation and firm compensation strategies

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Program and project management

  • Significant program governance and oversight support
  • Executive reporting and communication delivery
  • Outstandingproject management expertise

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Contact us

Arjun Saxena

Principal, Financial Services, Strategy&, PwC US

Bernadette Geis

Asset and Wealth Management Leader, PwC US

Julien Courbe

Financial Services Leader, PwC US

Chris Joline

Principal, Financial Services Advisory, Insurance, PwC US

Lisa Herrnson

Managing Director, Compensation and Employee Benefit Plans, PwC US

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