The American Retirement Association wrote to the Department of Labor to ask for an extension of the transition period and delay of the applicability date of the Fiduciary Regulation recommending a “tiered” approach to determine the applicability date for the delayed provisions of the Best Interest Contract Exemption, the Principal Transaction Exemption, and amendments to PTE 84-24. Under this approach, the delayed guidance would become applicable as of the later of July 1, 2019 or a date that is at least 18 months from the date a revised exemption (or rule) is issued.