Are Employees Giving Advice Considered Fiduciaries Under DOL Rule?

Fred - I would agree with Thompson Coburn's read on providing advice by employees, which I find quite problematic and in need of refinement by the DOL. Just imagine HR, or other personnel with little or no expertise, providing investment advice to their fellow employees. I would like to see the DOL expand its definition of "advice" to include employees of the plan sponsor regardless of compensation received.