Advisers who presently are fiduciaries may be especially likely to fully satisfy the PTEs»
Impartial Conduct Standards before January 1, 2018, in the ERISA - plan context, because advisers who make
recommendations to plans and plan participants regarding plan assets, including
recommendations on
rollovers or distributions of plan assets, are already subject to standards of prudence and loyalty under ERISA and a violation of the
Impartial Conduct Standards would be subject to claims for civil liability under ERISA.