Making the DOL Rule Work(flow): Your Questions Answered

questionblogLast week’s webinar, “Workflow Your Way to the DOL Deadline,” featuring Missy Pohlig, Redtail’s Rick Williamson and me was a first. Why a first?

  • Not because we had over 1300 advisors register (we’ve done a few with a larger audience)
  • Not because we had a guest expert (we’ve featured other experts before – but Rick was great)
  • Not because we announced new tools and ways to create efficiency in advisors’ offices (that’s kind of our thing)
  • Not for the pictures Raef Lee posted before the webinar on Twitter (like this one and this one – he likes posting unflattering photos)

It was a first because SEI, one of the largest TAMPs, and Redtail, one of the most popular CRMs for advisors, launched a product to help advisors navigate the DOL strategy and provided some action steps using workflows. And we gave them away for free. That’s right, the advisors on the call didn’t have to be SEI or Redtail clients to receive the four documented workflows – one strategy session for their office and three tactical sessions for use on client accounts (depending on the decision to move, hold or orphan the account).

Questions abound

We covered a brief overview of the DOL rule, an intro to the workflows, a demonstration of how they work and how they fit into a CRM. But even with all the detail, there were still plenty of questions, both during the call and via email over the last few days.

I decided it would be best to answer some of the more frequent questions, with the idea that if two or three of you were asking, many more were wondering.

Q: Will there be a recording of the presentation and will I get access to the slides?

A: Without a doubt, it’s the most asked question. If you registered for the webinar, you should have received the slides, recording and toolkit already. If you missed it, here’s how you can get your DOL workflow toolkit.

Q: Redtail?

A: There were lots of questions about how to get the workflow, what version of Redtail you’d need, and what happens if you don’t use Redtail. First, the workflows were loaded into the Project Tailwag (only) version of Redtail on Monday, October 31.

  • If you used your Redtail user name when you originally signed up or for the webinar, the workflows were added to your CRM on October 31.
  • If you register at the link above and used your Redtail user name, expect it to take up to a week before you see the workflows.
  • If you are not using Redtail, the manuals and swim lane diagrams will still be useful, whether you incorporate them into your CRM or use them as a manual.

Q: Can you explain level fees again?

A: Questions came fast and furious over the term “level fees” and when you would need a full BIC or a BIC “lite.” To me, the most simplistic way to explain would be to say that there can be no financial incentive to choose one product or implementation over another. The level fee advisor would typically be paid as a percent of assets by the investor, not the sponsor. (Point of clarification: some investments pay the advisor a percent of assets, but the advisor is actually a solicitor, not an advisor or co-advisor. Please be sure to check how your agreement is worded). Level fee advisors would typically use the BIC “lite,” which requires advisors to comply with the same fiduciary standards, but does not require a full BICE contract.

Also, using breakpoints in fees, such as reducing the asset-based fee charged as the account value increases (as long as still coming from the client), would not typically violate the level fee.

There have been many questions about level fees; the good news is that the DOL released an FAQ a few days ago that basically confirms a position that the DOL considers level fees to be very limited and generally fees paid by the account owner. Please see https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/faqs/coi-rules-and-exemptions-part-1.pdf

Q: Do you have any other workflows, like planning review, quarterly account review, etc.?

A: SEI and Redtail created a program called ProcessWise, which includes 48 workflows. To learn more, contact your SEI representative.

Q: Are you going to address the RIA who does not have a Broker Dealer?

A: The non-BD-affiliated advisor should, in my opinion, still use the strategic workflow. There is value in understanding the rule and how it may affect your business.

Q: Why are you giving these workflows away?

A: Since the law become public this spring, most of the conferences, articles and conversations have all been about the rule itself, not what to do about it. We built the manuals, workflows and swim lane diagrams specifically to give advisors the steps they need to get started. They are easy to edit in the event your BD has policies in place, or if there are clarifications to the rule. By launching the strategy workflow in the first week in November, you should be ready to start executing your marketing, execution and project plans by the first of the year.

The key theme around the DOL: Document everything. Using workflows (especially if they are in your CRM) is a great way to “defend” your process and procedures. As Ricky said in our webinar, “If it’s not in the CRM, it didn’t happen.” So all you advisors out there – make it happen.

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John Anderson

John Anderson

John Anderson is the creator and lead author of Practically Speaking blog and Managing Director of Practice Management Solutions for the SEI Advisor Network.

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