Florham Park counsel Joan Neri authored an article for the National Association of Plan Advisors' (NAPA) July 2012 newsletter. The article is titled, "DOL Issues Guidance on Participant Disclosure of Asset Allocation Models."
Joan, counsel in the Employee Benefits & Executive Compensation Practice Group, notes that the Department of Labor’s (DOL) Field Assistance Bulletin 2012-02 has provided some much needed guidance for RIAs on the application of the participant disclosure rules to asset allocation models (AAMs).
Joan discusses the typical features of an AAM and the DOL’s position. She concludes that, “using the DOL’s guidance as a roadmap, RIAs who offer asset allocation services should evaluate whether they need to be restructured as qualifying asset allocation services in order to avoid DIA status.”
To read the entire article, click here.