Calling all Chief Compliance Officers (CCO):Don’t Miss the June 30th Deadline:
Financial Firms Must Complete Their PTE 2020-02 Retrospective Review Soon!
If your financial advisers rely on Prohibited Transaction Exemption (PTE) 2020-02, you’re likely aware of the obligations it brings—but one deadline looms larger than most: June 30th.
That’s the due date for your required annual retrospective review, and skipping it isn’t just an oversight—it is a HUGE compliance risk.
Let’s break down why this matters and how you can make it easier.
Why the Retrospective Review Matters
PTE 2020-02 allows financial professionals to receive compensation (such as advisory fees, commissions or 12b-1 fees) for rollover recommendations and other conflicted advice—as long as certain conditions are met.
One of those conditions is conducting an annual retrospective review of your firm's compliance with the exemption.
This review isn’t just a box to check!
It’s a safeguard designed to protect investors and demonstrates that your firm acted in your client’s best interest throughout the year. The DOL expects it to be thorough, objective, and well-documented.
If it’s not done—or done poorly—you’re exposing yourself to unnecessary risk, including regulatory scrutiny or loss of the exemption.
That’s right, the DOL can prevent you from doing any more rollovers for up to 10 years!
What the Review Should Include
Your retrospective review must:
Review your current process, forms and documentation
Assess how your firm complied with each condition of the exemption
Be reasonably designed to detect and prevent violations by reviewing a sampling of last year’s Rollover Forms
Be reviewed and certified in writing by a senior executive
Be completed within six months of the end of your review period (typically June 30 if you operate on a calendar year)
Don’t Go It Alone: Help Is Available
If the idea of knowing all the rules and pulling this together sounds overwhelming—you're not alone.
Many advisers and compliance teams are still trying to make sense of the DOL’s evolving guidance.
That’s why we created the ERISA Best Practices CE Course, available now at ERISANerd.com.
This on-demand course is packed with:
✅ Plain-English explanations of PTE 2020-02 requirements
✅ Sample documents, including a retrospective review checklist and executive certification template
✅ Actionable best practices to stay on the right side of regulators
Whether you need a refresher or a full walkthrough, this course is your shortcut to confidence.
And since you have read this far, you are eligible for $100 off the course by using “IAR100”.
Final Word: Don’t Wait Until the Last Minute
Compliance isn’t optional—and neither is the June 30th deadline.
Make time in the next few weeks to finalize your firm’s retrospective review, certify it properly, and keep it in your compliance files.
Need help getting it right? Start the course now.
Let’s make sure your firm stays compliant, protected, and prepared.