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The DOL and CAPTRUST’s No Golf Ball Rule

Dear CAPTRUST Clients:

On April 6, the U.S. Department of Labor released the final version of its long-awaited regulation intended to eliminate conflicts of interest for those in the financial services industry who advise on retirement assets.

These new rules will require anyone advising on retirement assets—either in a qualified plan or in an individual retirement account—to acknowledge fiduciary status and act exclusively in investors' best interests. This, no doubt, will benefit a great many people. Yet, as simple as this seems, it will be a tremendous challenge for many in our industry to comply with these requirements. The murky economics and questionable business practices of many of our competitors will be difficult to untangle.

As a CAPTRUST client, you need to know that we have always adhered to fiduciary standards, and, as you know, we acknowledge it in our contracts. We are proponents of this new regulation. We feel it is a validation of our business model and is the right way to do business. Working in our clients’ best interests has always been—and will continue to be—at the heart of what we do.

Our No Golf Ball Rule is a great example of how we have embedded these ideas in our business practices and culture. This might seem like a strange name for a corporate policy, so please allow me to explain.

At CAPTRUST’s inception, we committed that we would maintain a pristine reputation for providing completely objective advice to our clients. We vowed to never accept anything of any value from an investment manager or retirement plan service provider. This includes everything from pay-to-play arrangements to vendor sponsorships of company events to lunches, dinners, trips—not even as much as a golf ball. While accepting these payments and gratuities were and still are commonplace in our industry, we decided to forge a different path.

We have always found that the No Golf Ball Rule makes us an outlier in our industry, but to operate otherwise, we believe, would compromise our independence and objectivity. 

We will be speaking with you more in the coming months about the new rules, what they mean for you, and how we will help you monitor many of your service providers whose responsibilities have changed due to this rule. In the meantime, I hope you take comfort that we take our fiduciary responsibilities very seriously. We are honored that you have placed your trust in us.

All the best,

Fielding Miller
Co-founder and Chief Executive Officer



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