05/06/2026
The DOL's proposed six-factor prudence rule has been celebrated by private equity firms, real estate funds, and cryptocurrency platforms since the day it dropped. The early commentary has been dominated by asset managers and their attorneys, not by the participants the rule should ultimately protect.
Last week, we submitted a formal comment letter urging the DOL to close three significant gaps before finalizing the rule:
1. Close the CIT Fee Transparency Gap
2. Move Beyond Disclosure on Crypto — Participants Need Real Protections
3. Give Participants Transparency Rights That Match the New Protections for Fiduciaries
The comment period is still open. The final rule will be shaped by who speaks up.
🔗 Read our full breakdown here: https://hubs.ly/Q04fDcyz0
🔗 Read the press release: https://hubs.ly/Q04fCYXk0
Employee Fiduciary submitted a formal comment to the DOL on its proposed six-factor prudence rule. We support the framework — but urge three fixes before finalization: CIT fee transparency, crypto safeguards, and participant disclosure rights.