The DOL has issued a temporary policy stating that it will not bring enforcement actions against firms that are not Rule compliant by April 10. In other words, DOL will not bring enforcement actions against advisers for the “gap” period between April 10 and the date on which the DOL officially delays the Rule (if it, in fact, delays the Rule). If the DOL decides to not delay the Rule at all, firms have a “reasonable” period of time in which to send out the required disclosures and otherwise get compliant.

https://www.dol.gov/agencies/ebsa/employers-and-advisers/guidance/field-assistance-bulletins/2017-01