FSI-Oxford Economics: DOL’s Retirement Security Rule Would Result in Over $2.5 Billion in Costs & 120 Million Pieces of Paper Annually

January 17, 2024

Study finds proposed rule will harm Main Street investors’ access to professional financial advice, products and services

Today, the Financial Services Institute (FSI) released a study conducted with Oxford Economics analyzing the potential impact of the Department of Labor’s (DOL) recently proposed Retirement Security Rule.

After collecting relevant data from independent financial services firms and conducting research, the study determined that the DOL’s proposed rule would result in significant costs, impose undue burdens, and adversely affect Main Street American investors’ ability to access professional financial advice, products, and services.

“The study confirms our concerns about the DOL’s proposed Retirement Security Rule and its negative impact on the accessibility of financial advice for Main Street Americans as they prepare for retirement,” said FSI President and CEO Dale Brown. “If approved, the rule would impose unnecessary and expensive requirements on our members, further restricting Main Street American investors’ access to professional financial advice, products, and services. The proposed rule would impose unnecessary and expensive requirements on top of the existing requirements of current regulations like the SEC’s Reg BI and DOL’s PTE 2020-02. Given the findings of this study along with the concerns outlined in our recent comment letter, we urge the Department to withdraw the proposal.”

Study highlights include:

  • The FSI-Oxford Exonomics industry survey projects costs significantly higher than DOL’s estimates.
    • The proposed rule will cost firms $2.7 billion in the first year, 11 times the Department’s estimate of ongoing costs. The rule will continue to cost $2.5 billion each subsequent year.
  • In addition to electronic disclosures, FSI members expect advisors to print approximately 120 million pieces of paper annually to comply with the proposal.
  • In its analysis, the Department relied solely on data collected before Reg BI and PTE 2020-02 went into effect.
  • The DOL’s regulatory impact analysis too lightly dismisses the proposal’s impacts on small investors.
  • The DOL claims there will be alternative options for small investors, failing to mention that those options have limitations in terms of costs, conflicts, personalization, product shelf, etc.
  • The DOL has pointed to only purported qualitative benefits in support of the rule, which are negated by a reasonable quantitative analysis of the costs:
    • The literature cited by the DOL to support these benefits is outdated, preceding the effective date of Reg BI.
    • FSI members produce compliance costs that are greater than the costs estimated in the regulatory impact analysis.

Click here to download the full study.


  • In consultation with FSI, Oxford Economics prepared and distributed an online survey to representatives at FSI Member Firms. The survey was in the field between November 20 and December 6, 2023, and collected 15 responses from independent financial services firms that represent approximately 26,000 financial advisors. Respondents were asked about their expected costs to implement the proposed 2023 Fiduciary Rule, as well as their costs to comply with Reg BI, and, for upfront costs, with the vacated 2016 Fiduciary Rule and PTE 2020-02.
  • Based on the estimated total costs for the Respondents’ organizations, Oxford Economics calculated costs on a per-financial advisor basis. The median per-financial advisor cost was then scaled to project industry-wide estimates.
  • Member firms were asked to estimate their total costs for their organizations, including their independent affiliates. The results were then calculated on a per-financial advisor basis and scaled to financial advisors nationally based on FINRA Data.
  • To calculate industry-level impact, Oxford Economics multiplied the per-financial advisor estimated values by the total number of impacted financial advisors for each rule.
  • Compensation assumptions from the NPRM were used to calculate the total costs associated with staff time.