Forgot your password?

Please enter the email address you used when registering.

Invalid login
An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later. An error occurred while validating your email address. Please try again.

Email sent

Please check your email for password reset instructions.

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

An error occurred while processing your request. Please try again later.

An error occurred while processing your request. Please try again later.

Two-step verification

In order to change your password, we need to verify your identity. We have sent an authorization code to the email address on file.

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Two-step verification

Enter the 6-digit code sent to your email

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Please create a new password

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.
  • Must be at least 9 characters long
  • Must have at least one capital letter
  • Must have a number
  • Must have a special character
  • Cannot contain any characters that repeat more than twice
  • New passwords fields must match

An error occurred while processing your request. Please try again later.

An error occurred while processing your request. Please try again later.

Password successfully reset.

Two-step verification

In order to change your phone number, we need to verify your identity. We’ll send an authorization code to your email on file

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Please enter you new phone number

Invalid number
Invalid country code
Number is too short
Number is too long
Invalid number
Invalid number
An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later. An error occurred while registering your account. Please try again.

Your account phone number has been changed successfully

Invalid login

Enter your password to login.

Invalid login
Invalid login
An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.
Forgot password?

Two-step verification

To verify your identity, we need to send an authorization code to the email address on file.

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Two-step verification

Enter the 6-digit code sent to your email

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.
Resend the email

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Please enter a valid phone number.

We need a phone number to keep your account secure. We'll send you a code to validate your phone number right now.

Invalid number
Invalid country code
Number is too short
Number is too long
Invalid number
Invalid number

Forgot your password?

Please enter the email address you used when registering.

Invalid login
An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later. An error occurred while validating your email address. Please try again.

Email sent

Please check your email for password reset instructions.

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

An error occurred while processing your request. Please try again later.

An error occurred while processing your request. Please try again later.

Two-step verification

In order to change your password, we need to verify your identity. We have sent an authorization code to the email address on file.

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Two-step verification

Enter the 6-digit code sent to your email

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Please create a new password

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.
  • Must be at least 9 characters long
  • Must have at least one capital letter
  • Must have a number
  • Must have a special character
  • Cannot contain any characters that repeat more than twice
  • New passwords fields must match

An error occurred while processing your request. Please try again later.

An error occurred while processing your request. Please try again later.

Password successfully reset.

Two-step verification

In order to change your phone number, we need to verify your identity. We’ll send an authorization code to your email on file

An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later.

Please enter you new phone number

Invalid number
Invalid country code
Number is too short
Number is too long
Invalid number
Invalid number
An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later. An error occurred while registering your account. Please try again.

Your account phone number has been changed successfully

Enter your email address

Invalid login
An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later. An error occurred while validating your email address. Please try again.
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An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. Invalid login Your account has been temporarily locked because of too many failed login attempts. Please try again later. The code entered has expired. Please request a new code to continue. The code entered is not valid. Please request a new code to continue. Email address format is not valid. Your account has not been verified. Please check your email for instructions on how to verify your credentials. Your account has been disabled. An error occurred while processing your request. Please try again later. Invalid login This account has reached its limit for daily password resets. Please try again in 24 hours. Password does not meet password strength requirements. Please try again. That password was recently used. Please enter a new one. Password is not strong enough. Password cannot contain any forbidden words. Password is a commonly used password. Password cannot contain common words. Password cannot contain repeating characters. Password cannot contain sequence of characters. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. The account information you provided does not match our records. This account is not authorized to perform the request you've initiated. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. An error occurred while processing your request. Please try again later. We are unable to log you out of all the application Password does not meet password strength requirements. Please try again. An error occurred while processing your request. Please try again later. An error occurred while registering your account. Please try again.

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Understanding the DOL’s definition of an investment advice fiduciary

On October 31, 2023, the U.S. Department of Labor (DOL) issued a proposed rule—Retirement Security Rule: Definition of an Investment Advice Fiduciary. This would amend the existing rule that defines when a person is an investment advice fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA) and the Internal Revenue Code of 1986 (the code). The DOL also issued proposed amendments to various class prohibited transaction exemptions (PTEs), which are intended to narrow and harmonize the exemptions available to address conflicts of interest regarding investment advice.

If the proposed rule and associated amendments are finalized, they'd significantly expand which parties may be considered investment advice fiduciaries under ERISA and the code. This would impose new and expanded requirements on investment firms and professionals.

Existing fiduciary rule

The proposed rule would replace the DOL’s “five-part test,” which was originally issued in 1975. Under the five-part test, individuals are a fiduciary only if they meet the following five elements:

  • Render advice about the value of securities or other property or make recommendations on the advisability of investing in, purchasing, or selling securities or other property
  • Provide advice on a regular basis
  • Provide advice pursuant to a mutual agreement, arrangement, or understanding with the plan or a plan fiduciary 
  • Advice serves as a primary basis for investment decisions on plan assets
  • Advice is individualized based on the plan’s needs

According to the DOL, the five-part test as applied to the current marketplace fails to capture many circumstances in which investors reasonably believe they’re receiving advice from a fiduciary. If adopted, the proposed rule would replace the five-part test with a new test that the DOL believes reflects the current marketplace and the intent of ERISA.

It’s important to note that the current regulation was drafted when IRAs were less common and 401(k) plans didn’t exist. Today, 401(k) plan participants and IRA owners are expected to make important, complex financial decisions and are, therefore, more likely to seek the help of investment advisers.

Proposed fiduciary rule

The proposed rule defines investment advice fiduciaries as individuals who perform the following:

  • Directly or indirectly (through or together with any affiliate) have discretionary authority or control—that may or may not be pursuant to an agreement, arrangement, or understanding—about purchasing or selling securities or other investment property for the retirement investor
  • Directly or indirectly (through or together with any affiliate) make investment recommendations to retirement investors on a regular basis as part of their business, and recommendations are in the retirement investors’ best interest and based on their particular needs or individual circumstances
  • Represent or acknowledge that they’re acting as a fiduciary when making investment recommendations

Amendments to prohibited transaction exemptions  

The DOL is also proposing amendments to related existing PTEs that are available to investment advice fiduciaries. These proposed amendments seek to make the exemption conditions more uniform and protective. 

Under ERISA, investment advice fiduciaries must avoid conflicts of interest or comply with the conditions of a PTE. The proposed amendments to the exemptions would uniformly require investment advice fiduciaries to give advice that:

  • Meets a professional standard of care or duty of prudence
  • Puts the retirement investor first (duty of loyalty)
  • Prohibits charging more than reasonable compensation or misleading investors

DOL objectives

According to the DOL, the proposed rule would ensure that when investors entrust their retirement security to investment firms and professionals, their confidence isn’t misplaced, regardless of what investment is recommended. The proposed rule would also assure that investment firms and professionals are able to compete for business on a level playing field, instead of an unbalanced system that holds advisers to different standards based on their recommended products. For example, investment firms and professionals would now be held to the fiduciary standard on rollover IRAs.

Reactions to the proposed rule

The proposed rule has been met with some criticism. Opposers feel this latest proposal imposes burdensome regulations that have already proven to make investing more difficult, especially for those who fall in the lower income levels. They’ll most likely advocate for changes to the proposed rule to ensure it’s administratively feasible for different business models, products, and services.

Conversely, proponents say updated fiduciary rules should better position employees for retirement. Since investment advice associated with 401(k) and other employer-sponsored plans isn’t subject to the SEC’s Regulation Best Interest and, therefore, not currently required to be in the customer’s best interest, the proposed rule will put the right focus on investment recommendations.

Next steps

The proposals include a 60-day period for public comments and instructions on how to submit comments, which is open until January 2, 2024. Additionally, the DOL plans to hold a public hearing on December 12 through December 13. Information on the hearing has been published in the Federal Register.

The content of this document is for general information only and is believed to be accurate and reliable as of the posting date, but may be subject to change. It is not intended to provide investment, tax, plan design, or legal advice (unless otherwise indicated). Please consult your own independent advisor as to any investment, tax, or legal statements made.

MGTS-PS  534057  11/23   534057

MGR1124233249991 

 

Chris Frank

Chris Frank, 

Head of Defined Contribution Consulting

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