Checklist for Amended Prohibited Transaction Exemption 2020-02

This document is a checklist outlining the high-level requirements for compliance with the Amended Prohibited Transaction Exemption (PTE) 2020-02, as published by the Department of Labor in April 2024. The checklist details the obligations of investment professionals and financial institutions regarding fiduciary status and the provision of investment advice under the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code (IRC). Key requirements include the necessity for written acknowledgment of fiduciary status, specific disclosures to retirement investors about the investment relationship and conflicts of interest, and adherence to impartial conduct standards. The document also emphasizes the importance of compliance with federal securities laws and outlines the procedures firms must establish to ensure adherence to these standards. Additionally, it mentions the need for firms to conduct annual retroactive reviews, correct any prohibited transactions, and maintain comprehensive records. Overall, the checklist serves as a guide for financial institutions to navigate the updated regulations effectively.