When the latest DOL fiduciary rule was vacated, a familiar narrative took hold: with the regulatory pressure off, firms would dial back the rigor of their rollover process. Less analysis. Lighter documentation. A return to “good enough.”

The data tells a very different story.

What we’re seeing in the platform

Across InvestorCOM’s rollover analytics platform, weekly utilization is not just holding — it’s accelerating year-over-year.

Weekly YoY utilization growth, January – April 2026. Every week up triple digits versus 2025.

Every single week of 2026 is up triple-digits versus the same week in 2025. Utilization is running nearly 3x last year’s pace. Advisors aren’t relaxing. They’re leaning in.

Why the conventional wisdom got it wrong

The assumption that a vacated DOL rule equals lighter compliance overlooks how the actual regulatory landscape works. As experts emphasized on our recent webcast The New Reality of Rollover Advice, the practical reality is unchanged:

• The 1975 five-part test for fiduciary status is back in force.
• PTE 2020-02 still governs conflicted rollover recommendations.
• Reg BI still requires firms to act in the client’s best interest, consider alternatives, and increasingly mitigate — not just disclose — conflicts.
• The SEC and FINRA continue to examine rollover recommendations.

“There’s both a fiduciary rule and a conflict of interest rule in every regulatory scheme.”

— Fred Reish, employee benefits attorney

Boilerplate justifications — “more options, better service” — are now a red flag. Examiners expect individualized analysis tied to the specific client: why the rollover, what alternatives were considered, how fees and services compare, and how the recommendation fits the client’s profile.

Utilization is the proof point

A few months ago, we wrote about why utilization is the metric that matters most — the clearest signal that clients are realizing real ROI from a compliance platform, not just buying shelfware. Twelve weeks into the year, utilization was already up ~168% versus 2025. Two months later, it’s higher still.

The takeaway for the industry is clear:

• The burden didn’t go away with the DOL rule.
• Firms that built defensible, repeatable rollover processes aren’t unwinding them — they’re running them harder.
• Best interest analysis is becoming a competitive standard, not a regulatory minimum.

If anything, the vacating of the DOL rule has clarified the picture: thoughtful, documented, individualized rollover analysis isn’t a reaction to one rule. It’s the through-line across every framework that still applies.

And the firms doing it well are the ones using it most.

Want to see what defensible, scalable rollover analysis looks like in practice?