On April 4, 2017, the Department of Labor (“DOL”) released for public inspection its final regulation extending the applicability date of the Fiduciary Rule from April 10, 2017 to June 9, 2017 as well as providing additional transition relief through the end of the year (the “Final Extension”).  While the Final Extension is a welcome development, it creates a series of significant new challenges for the retirement services industry.  In the attached memo, we first describe the specific changes in the Final Extension.  Then, we outline the challenges.