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DOL 2.0: Spotlight on New Forms

By April 26, 2022No Comments

You may recall in all communications relating to the Department of Labor, ESI has referred to doing business under two Prohibited Transaction Exemptions, also known as PTE 84-24 and PTE 20-02.

Compliance with PTE 84-24 took place in December of 2021.  It was largely focused on disclosure of third-party compensation from the recommendation to purchase insurance products such as fixed-indexed or variable annuities. 

PTE 20-02 has a compliance date of June 30th, 2022. By utilizing 20-02, reps can continue to receive third-party compensation for advice related to ERISA and IRA-based accounts, as long as certain criteria are met.  PTE 20-02 will be used for brokerage, mutual fund, and advisory business.  To comply with PTE 20-02 ESI has updated disclosures on various forms and created two new forms: the IRA-to-IRA Disclosure Form and the IRA Transfer of Assets Form.

New Forms
IRA to IRA Disclosure Form (Direct Mutual Fund and Advisory Business)

This form will be required when all of the following apply:

  • A transaction is occurring in an IRA account (new business or subsequent deposit)
  • Will be funded with transfer/rollover from another IRA
  • The destination of the funds is a non-annuity product.
  • Note: This form will also be utilized for Brokerage and Illuminations accounts that are being funded with an IRA through means other than a Transfer of Assets (60-day rollover, indirect rollover, Roth Conversion Rollover)

IRA Transfer of Assets Form (Brokerage and ESI Illuminations)
This form will be required when all of the following apply:

  • A transaction is occurring in an IRA account  (new business or subsequent deposit)
  • Will be funded with a Transfer of Assets from another IRA
  • The product used is either:
    • Brokerage Account
    • ESI Illuminations Account

Forms Availability
The form(s) will be available starting May 9th.  Although the deadline for using the new form is June 30th, making them available over one month early, gives time to get into the practice of using the form (s).  They will be found under the Optional Forms section in Docupace and can be added to the work item. They will also be available in Merrill.   

How to Complete the Form(s)

Reminder!  DOL education and training is available on the National Life Portal.  Simply click on the lightning bolt located in the upper right side of the main menu bar and scroll down to DOL Training Page. 

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