How are advisers coping with the new Department of Labor (DOL) rollover rules?

As of February 1st of this year, the DOL regards any recommendation to roll over assets from a 401(k) plan not managed by an adviser, to an IRA that IS managed by you to be a prohibited transaction — unless you can document, to the client and the satisfaction of a future auditor, that the rollover really is in his/her best interests. Moreover, the rule takes the position that the rolled-over assets in the IRA are now subject to ERISA