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The DOL’s New Prohibited Transaction Exemption (PTE) for Plans and IRAs; Yes, it’s finally here! (IA)(Intermediate)

October 27, 2021
11:00 AM - 12:00 PM PDT
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Course Description:

In February 2021, the DOL announced that PTE 2020-02 would become effective on February 16. The PTE, designed to replace the late, unlamented fiduciary rule from 2016, sets down the requirements for providing advice to ERISA plans and to IRAs. The PTE confirms the reinstatement of the five-part test for determining whether a person renders investment advice and defined the “impartial conduct standards” that are now a baseline for ERISA and IRA fiduciaries. The rule has far-reaching implications for firms recommending IRA rollovers, engaging in principal transactions, and more. This session will provide a foundation for understanding the new PTE and will include key concepts and definitions needed to identity potential compliance issues when working with retirement assets and investors.

Learning Objectives

After attending this session, you should be able to:

  • Analyze the basic requirements of the new PTE
  • Determine when a firm becomes an investment advice fiduciary and what is required
  • Re-evaluate your procedures for providing advice, making disclosures, and keeping required records

This course is being taught as part of the Fall 2021 In-Person Compliance Conference. To learn more, visit our main conference webpage.

Craig Watanabe
Director IA ComplianceDFPG Investments, LLC


Mr. Watanabe has been a Financial Adviser and the Director of IA Compliance at DFPG Investments, LLC. (“DFPG”) since April 2018. Mr. Watanabe entered the securities industry in 1983 and has been a successful financial planner, Branch Manager, Operations Manager, Chief Compliance Officer and Chief Operating Officer.

Mr. Watanabe has broker-dealer and investment adviser compliance experience covering retail brokerage, market making, research, investment banking. insurance, commodities, retail investment advisory and ERISA plans. In his current role as a financial adviser with DFPG, Mr. Watanabe works with clients to assist in growing and protecting their assets and planning to meet their financial objectives. DFPG is a registered broker-dealer and investments adviser. Mr. Watanabe is responsible for the investment adviser compliance program.

Mr. Watanabe served on the FINRA District 2 Committee from 2008-11 and was Chairman of the Committee in 2011. He also served six years on the NSCP Board of Directors and was Chairman of the Board in 2013. In 2020 Mr. Watanabe was the recipient of the NSCP Joan Hinchman Award for lifetime dedication to the compliance profession.

Mr. Watanabe is a frequent speaker at conferences and has authored numerous articles and training modules for financial professionals. Securities and advisory services are offered through DFPG Investments, LLC, Member FINRA and SIPC.


Rob Stirling
Executive ConsultantNRS


Rob Stirling has worked with NRS for much of the past four decades: from October 1991 to June 2000, from May 2002 to June 2004, on a part-time basis starting in December 2007, and returning full-time in August 2008. Rob is based in Miamisburg Ohio.

Rob has prepared, reviewed and/or updated hundreds of ADVs representing firms of all sizes and engaged in every aspect of investment advisory services. He has helped design and monitor specialized compliance programs for advisers based in Europe and Asia doing business in the United States and for Internet-based advisers. He regularly reviews advertising and marketing materials, including websites, for compliance with SEC guidelines. Rob has performed well over two hundred mock examinations of advisory firms, and he has spoken at numerous compliance conferences and seminars.

During his times away from NRS, Rob was himself a compliance officer. Rob was Chief Compliance Officer of PrivateAccounts, Inc. from July 2000 to October 2000; when that firm was purchased by E*TRADE Financial, Rob worked at E*TRADE as a Compliance Manager from November 2000 to May 2002. Rob was Chief Compliance Officer and General Counsel of Eubel Brady & Suttman Asset Management, Inc. from June 2004 through July 2008.

Rob earned a BA in Religion from the American University and a JD from the University of Connecticut School of Law. Rob has been admitted to the Connecticut Bar.

For Whom: Designed to increase the professional competence of Investment Advisers and Broker-Dealers.

Suggested Skill Level: Intermediate

Maximum Recommended Credit Hours for this session will include CLE, IACCP® and CPE.

CA MCLE = 60 minutes
IACCP® = 60 minutes
CPE = 60 minutes

For more information, check out the NRS Continuing Education Guide.