The American Retirement Association wrote to the Department of Labor to respond to the Department’s Request for Information regarding the Fiduciary Rule and Prohibited Transaction Exemptions. In the letter, the American Retirement Association recommends a delay of the January 1, 2018 applicability date for certain provisions of the Best Interest Contract Exemption, the Principal Transaction Exemption, and amendments to PTE 84-24 and recommends an alternative streamlined Levelized Fee Exemption.