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NAFCU comment letter to Department of Labor re: extension of Fiduciary Duty Rule date of applicability

WASHINGTON, DC (March 17, 2017) —  

Good afternoon,

Attached please find NAFCU Regulatory Affairs Counsel Andrew Morris’ letter to the Department of Labor regarding the proposed extension of the department’s, “Fiduciary Duty Rule.”

In the letter, Morris wrote, “NAFCU and our members are concerned that the Fiduciary Duty Rule casts a wide net that unfairly burdens credit union activity with complex requirements and potential litigation risk. For example, the requirements of the rule are triggered when an individual provides a “recommendation,” which is defined as a “a communication that, based on its content, context, and presentation, would reasonably be viewed as a suggestion that the advice recipient engage in or refrain from taking a particular course of action.”

“NAFCU believes that there is little merit in requiring credit unions to comply with a complex fiduciary duty requirement when there is minimal, if any, data indicating that potential conflicts of interest have negatively impacted credit union member service. Conversely, there is no shortage of evidence describing the costs and accompanying reduction in consumer choice that would follow enforcement of the rule.”

If you would like more information on this matter or would like to speak about this with a NAFCU expert, please let me know.

 


About NAFCU

The National Association of Federally-Insured Credit Unions is the only national trade association focusing exclusively on federal issues affecting the nation’s federally-insured credit unions. NAFCU membership is direct and provides credit unions with the best in federal advocacy, education and compliance assistance. For more information on NAFCU, go to www.nafcu.org or @NAFCU on Twitter.

Contacts

Molly Safreed, msafreed@nafcu.org (NAFCU)

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