K. Susan Grafton
Washington, D.C. +1 202 261 3399
New York +1 212 698 3611
The U.S. Department of Labor issued Field Assistance Bulletin 2017-01 (FAB) on March 10, 2017. The FAB announced a temporary enforcement policy pursuant to which the DOL will not initiate any enforcement action under its new Fiduciary Rule (i) because of any "gap"-period noncompliance, if the April 10, 2017 applicability date of the rule is not extended until after April 10, or (ii) if the applicability date is ultimately not extended, provided that there is compliance with the rule within a reasonable period.