Amended Prohibited Transaction Exemption 84-24 Checklist

This document is a checklist designed to assist independent producers (IPs) in complying with the Amended Prohibited Transaction Exemption (PTE) 84-24, published by the U.S. Department of Labor (DOL). The checklist outlines the major requirements of PTE 84-24, which is effective from September 23, 2024, and includes a year-long phase-in period for IPs to receive compensation for non-security insurance contract sales. Key requirements for IPs include providing written fiduciary acknowledgment to retirement investors, disclosing material facts about conflicts of interest, and adhering to impartial conduct standards. The document also specifies that financial institutions must assess IPs' qualifications, ensure compliance with compensation standards, and conduct annual reviews of IPs. Additionally, it clarifies that certain compensation structures and practices must be avoided to prevent conflicts of interest. Overall, the checklist serves as a practical guide for IPs and firms to navigate the regulatory landscape surrounding fiduciary responsibilities.