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Timeline of DOL Rule Specific Milestones and Deadlines

The road to the proposed “best interests” standard is long and splintered, dating back to 1933, when the first law was signed to regulate the banking industry. Until the fiduciary rule, regulation was industry-specific. The DOL Rule is the first regulation aimed at reconciling and unifying all businesses in the financial service profession under a single fiduciary standard. The following timeline includes milestones related to fiduciary duties and the rise of the DOL fiduciary rule.

  • 1933

    Banking Act Signed -
    First law passed to regulate the banking industry.

  • 1934

    Securities and Exchange Act Signed -
    Securities and Exchange Commission (SEC) formed

  • 1940

    Investment Advisers Act -
    first law noting fudiciary obligation to clients, signed

  • 1945

    McCaran-Ferguson Act signed -
    Exempted the insurance business from most federal regulation to an extent.

  • 1963

    SEC V. Capital Gains Research Bureau -
    fiduciary intent of Investment Advisers Act confirmed

  • 1974

    September 2, 1974 -
    ERISA (Employee Retirement Income Security Act of 1974) signed into law by President Gerald Ford

  • 1975

    October 31, 1975 -
    DOL issues Reg. §2510.3-21(c) which defines the circumstances when a person renders “investment advice” as a fiduciary under ERISA

  • 1995

    Committee on Compensation Practices -
    suggests fee-based accounts to minimize conflicts

  • 1999

    SEC Rule on Fee-based Brokerage Accounts -
    rule propsed to exempt brokers' fee-based accounts from fudiciary requirements

  • 2005

    The “Merrill Lynch” Rule -
    SEC re-proposes the 1999 exemption rule, The Financial Planning Association sues

  • 2007

    FPA Wins -
    Merrill Lynch Rule is vacated, brokers must adhere to fiduciary duty

  • 2009

    Treasury Report Suggests Harmonized Regulation -
    Report proposes the SEC establish fiduciary duty and harmonize regulation of investment advisors and broker-dealers

  • July 2010

    Dodd-Frank Law signed -
    Gives the SEC authority to reinforce a financial duty standard for retail investment

  • September 2010

    DOL Releases Fudiciary Rule

  • January 2011

    SEC Report Favors Uniform Fiduciary -
    SEC supports the rule, recommends fiduciary duty

  • September 2011

    Industry Fights Back -
    The DOL withdraws its fiduciary rule due to fierce industry criticism

  • March 2013

    SEC Seeks Cost-Benefit Feedback -
    Parameters of a fiduciary outlined in an SEC request for cost and benefits information

  • July 2013

    Thomas Perez Confirmed as Secretary of Labor -
    Promises to listen to stakeholders before deciding how to proceed with the fiduciary rule

  • February 2015

    Obama Demands Progress -
    Directs DOL to repropose the fiduciary duty rule

  • March 2015

    SEC Announces Support -
    Chairwoman Mary Jo White announces support of fiduciary duty rule

  • April 2015

    DOL Re-proposes the Rule -
    New rule is proposed as per Obama’s demands

  • April - September 2015

    Comment Period and Hearings Through September -
    DOL receives more than 3,000 letters with comments about the proposed rule

  • September 29, 2015

    Latest Date by Which Congress Could Pass a Joint Resolution of Disapproval

  • October 2015

    Political Sides are Drawn -
    Legislation introduced to block the bill

  • January 2016

    Rule Heads to OMB -
    Rule is sent to the Office of Management and Budget for review

  • April 2016

    DOL Releases the Final Rule -
    The Labor Department releases its final version of the fiduciary rule on April 6

  • April 2016

    Final Rule Published in the Federal Register -
    April 8

  • December 2016

    Final Rule Becomes Effective

  • February 3, 2017

    Trump administration issues a memorandum ordering the DOL to officially review the fiduciary rule.

  • March 2017

    DOL responds to the Trump directive by proposing a new rule which extends the initial ruling’s implementation date by 60 days.

  • March 2017

    A 15-day public comment period on the new ruling, and a 45-day public comment period on the presidential memorandum are initiated by the DOL.

  • April 2017

    Original Phase 1 compliance deadline -
    April 10, 2017 deadline extended by 60 days.

  • June 2017

    Updated Phase 1 compliance deadline -
    Per the DOL’s update, the new Phase 1 implementation deadline is June 9, 2017.

  • January 2018

    Full Compliance Required -
    By January 1

  • 1933

    Banking Act Signed -
    First law passed to regulate the banking industry.

  • 1934

    Securities and Exchange Act Signed -
    Securities and Exchange Commission (SEC) formed

  • 1940

    Investment Advisers Act -
    first law noting fudiciary obligation to clients, signed

  • 1945

    McCaran-Ferguson Act signed -
    Exempted the insurance business from most federal regulation to an extent.

  • 1963

    SEC V. Capital Gains Research Bureau -
    fiduciary intent of Investment Advisers Act confirmed

  • 1974

    September 2, 1974 -
    ERISA (Employee Retirement Income Security Act of 1974) signed into law by President Gerald Ford

  • 1975

    October 31, 1975 -
    DOL issues Reg. §2510.3-21(c) which defines the circumstances when a person renders “investment advice” as a fiduciary under ERISA

  • 1995

    Committee on Compensation Practices -
    suggests fee-based accounts to minimize conflicts

  • 1999

    SEC Rule on Fee-based Brokerage Accounts -
    rule propsed to exempt brokers' fee-based accounts from fudiciary requirements

  • 2005

    The “Merrill Lynch” Rule -
    SEC re-proposes the 1999 exemption rule, The Financial Planning Association sues

  • 2007

    FPA Wins -
    Merrill Lynch Rule is vacated, brokers must adhere to fiduciary duty

  • 2009

    Treasury Report Suggests Harmonized Regulation -
    Report proposes the SEC establish fiduciary duty and harmonize regulation of investment advisors and broker-dealers

  • July 2010

    Dodd-Frank Law signed -
    Gives the SEC authority to reinforce a financial duty standard for retail investment

  • September 2010

    DOL Releases Fudiciary Rule

  • January 2011

    SEC Report Favors Uniform Fiduciary -
    SEC supports the rule, recommends fiduciary duty

  • September 2011

    Industry Fights Back -
    The DOL withdraws its fiduciary rule due to fierce industry criticism

  • March 2013

    SEC Seeks Cost-Benefit Feedback -
    Parameters of a fiduciary outlined in an SEC request for cost and benefits information

  • July 2013

    Thomas Perez Confirmed as Secretary of Labor -
    Promises to listen to stakeholders before deciding how to proceed with the fiduciary rule

  • February 2015

    Obama Demands Progress -
    Directs DOL to repropose the fiduciary duty rule

  • March 2015

    SEC Announces Support -
    Chairwoman Mary Jo White announces support of fiduciary duty rule

  • April 2015

    DOL Re-proposes the Rule -
    New rule is proposed as per Obama’s demands

  • April - September 2015

    Comment Period and Hearings Through September -
    DOL receives more than 3,000 letters with comments about the proposed rule

  • September 29, 2015

    Latest Date by Which Congress Could Pass a Joint Resolution of Disapproval

  • October 2015

    Political Sides are Drawn -
    Legislation introduced to block the bill

  • January 2016

    Rule Heads to OMB -
    Rule is sent to the Office of Management and Budget for review

  • April 2016

    DOL Releases the Final Rule -
    The Labor Department releases its final version of the fiduciary rule on April 6

  • April 2016

    Final Rule Published in the Federal Register -
    April 8

  • December 2016

    Final Rule Becomes Effective

  • February 3, 2017

    Trump administration issues a memorandum ordering the DOL to officially review the fiduciary rule.

  • March 2017

    DOL responds to the Trump directive by proposing a new rule which extends the initial ruling’s implementation date by 60 days.

  • March 2017

    A 15-day public comment period on the new ruling, and a 45-day public comment period on the presidential memorandum are initiated by the DOL.

  • April 2017

    Original Phase 1 compliance deadline -
    April 10, 2017 deadline extended by 60 days.

  • June 2017

    Updated Phase 1 compliance deadline -
    Per the DOL’s update, the new Phase 1 implementation deadline is June 9, 2017.

  • January 2018

    Full Compliance Required -
    By January 1