DOL arms investors with rollover questions that could catch some advisers off guard The timing of those questions, such as 'are you a fiduciary?' is not great for advisers relying on the DOL’s temporary enforcement policy until Dec. 20, the compliance deadline for the new rules, one lawyer said. April 20, 2021 3 MINS The DOL issued guidance last week about the fiduciary implications of rollover recommendations – but a set of questions it published the same day for account holders could create problems for some advisers. The regulator last Tuesday published a set of answers to frequently asked questions about part of the Trump-era fiduciary rule, the prohibited transaction exemption dubbed Improving Investment Advice for Workers & Retirees. The guidance clarified that a recommendation to roll funds from an employer-sponsored retirement plan to an individual retirement account can represent the beginning of an ongoing fiduciary relationship between an adviser and a client. In February, the DOL announced that it would not seek to halt or overturn the Trump-era rules that were finalized late last year, although the agency said it would soon issue guidance and could later make changes to the rules.