PTE 2020-02 Provide best interest rollover advice.
The Department of Labor’s (DOL) PTE 2020-02 expands the definition of fiduciary advice when recommending rollovers, making documentation and client disclosure an explicit requirement of its proposed prohibited transaction exemption.
Key requirements of PTE 2020-02.
Best Interest Rollover Analysis
Provide investment advice that’s in the best interest of the client.
RolloverAnalyzerRetrospective Compliance Review
Document and disclose reasons for rollover recommendations.
RolloverAnalyzerWe help Broker-Dealers and RIAs meet the PTE 2020-02 requirements.
A single workflow for making compliant rollover recommendations
In a 2022 survey, 50% of firms stated that they are using a manual process to make rollover recommendations and 57% will meet their retrospective review requirements via a manual audit. Manual processes are widely considered to be unsustainable and open the firm up to potential operational risks and compliance breaches.
RolloverAnalyzer provides a single workflow for making compliant recommendations:
- Compare rollover options across Client Fit, Service Level and Costs
- Integrates Form 5500 and benchmark data
- Auto-generates client reports and “reasons why” to support the recommendation
- Document and disclose the recommendation to the client
- Monitor and analyze rollover activity across the entire firm and identify risk-based scenarios for self-correcting
- Export data for regulatory reporting
- Validate rollover data with new account openings
New in RolloverAnalyzer
Cost lookups and AI supervision, built in.
IRA Fee Lookup
Find and document existing IRA fees in seconds.
- Search fee schedules sourced from Form ADV filings and refreshed monthly.
- Calculate the estimated annual cost based on the client’s balance.
- Add the fee, methodology, and source directly to the rollover analysis.
Plan Investment Lookup
Calculate investment costs from the client’s actual holdings.
- Access the plan’s investment lineup using Form 5500 data.
- Enter allocations directly from the client’s account statement.
- Automatically calculate the weighted expense ratio and add it to the rollover analysis.
Product Cost Lookup
Build complete, product-specific cost comparisons.
- Search current product data across securities and annuities.
- Build and allocate securities portfolios or configure annuity riders and surrender schedules.
- Automatically calculate the applicable costs and add them directly to the rollover analysis.
Supervision Agent
Use AI to supervise every rollover. Focus human effort on the exceptions.
- AI reviews every rollover in real time against firm policy.
- Reduces manual review by prioritizing the highest-risk cases and explaining why they need attention.
- Recommends approve, flag, or review, while supervisors retain the final decision.
Meet compliance for Reg BI and PTE 2020-02.
| Requirement | SEC: Reg BI | DOL: PTE 2020-02 | RolloverAnalyzer |
|---|---|---|---|
| Evaluate |
|
| |
| Fees | Essential element for the recommendation | Reasonable estimation of expenses, asset values, risk and returns based on publicly available information. | |
| Documentation | Good risk mitigation | ||
| Retrospective Review | |||
| Client Disclosure | |||
| Recordkeeping | Good risk mitigation |
What Our Clients Say
“We recognize that meeting the PTE 2020-02 requirements is most efficiently accomplished by utilizing compliance technology – there are far too many factors for an advisor to consider. InvestorCOM’s RolloverAnalyzer checks all the boxes within a single workflow and does it simply and intuitively.”
Ryan Carlson
Principal, American Independent Securities Group (AISG)
“InvestorCOM delivers on having a ‘proudly simple’ platform supported by exceptional service. Their partnership-minded approach has supported our ability to create solutions tailored to our unique business needs.”
Jamie Wieferich
SVP, Chief Operating Officer, Wealth Management, D.A. Davidson & Co.
“Using purpose-built compliance technology to meet the PTE 2020-02 requirements makes business sense. An advisor could spend several hours aggregating cost data and assessing, documenting, and disclosing a single rollover recommendation. With access to a comprehensive rollover analysis tool, our Financial Advisors can easily document their comprehensive discussions with clients about moving their retirement dollars.”
Risa Gomez
First Vice President of Retirement Plan Services at Davenport & Company LLC
Resource
SEC and DOL: Rollover Requirements
Eversheds Sutherland discusses the DOL and SEC’s expectations, how to make compliant rollover recommendations, and more.
White Paper
Reg BI, Fiduciary Rule 3.0 and the Emergence of Pre-trade Compliance
This white paper explores the new pre-trade requirements and their impact on wealth management firms.
Resource
Reg BI and PTE 2020-02 Compliance Priorities
Industry experts discuss the regulatory challenges and opportunities presented by Reg BI and PTE 2020-02.