For much of the past year, the broker-dealer community has lamented that the proposed DoL fiduciary rule would be a significant impediment to their business model, causing additional compliance burdens and greater costs for their brokers and ultimately consumers. Yet with the final DoL fiduciary rule issued, the question now arises about what brokers who work at a broker-dealer should actually do, given the rules that are scheduled to take effect next April of 2017.
In this week’s #OfficeHours with @MichaelKitces, my Tuesday 1PM EST broadcast via Periscope, we look at how the DoL fiduciary rule will likely splinter the broker-dealer community into three types of broker-dealers: the level-fee fiduciary broker-dealer, the full-BIC broker-dealer, and the non-qualified-only broker-dealer, each of which will have different compliance obligations, different products and services available, and different limitations on the oversight and scope of advice their brokers can provide.
Notably, the decision of what type of broker-dealer the organization will be in the future is ultimately up to the broker-dealer itself, and advisors will simply have to decide whether they're happy to continue under that broker-dealer structure, or seek out another type instead. Or possibly leave the broker-dealer environment altogether and become an RIA instead.
Which means for an advisor currently at a broker-dealer, there's really no reason to make a change... yet. But it's imperative that advisors at broker-dealers begin to consider what kind of business they want to operate in the future, and whether it's really necessary to continue offering commission-based products and deal with the additional compliance burdens, or choose to focus as a level-fee fiduciary instead. And then when the broker-dealer makes the announcement of what it will be, likely sometime over the next six months, the path of whether to stay or go should become much clearer...