It’s time to look at your books of business

Ary Rosenbaum - The Rosenbaum Law Firm P.C.
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The Rosenbaum Law Firm P.C.

Broker-dealers are certainly in a bind to comply with the new Fiduciary Rule and one aspect is sending disclosures to IRAs and qualified plans. This may be a good time for all type of plan providers such as brokers, registered investment advisors, and third party administrators to take a stock of their plans that are on their books.

Broker-dealers may find qualified plans on the books for companies that may no longer exists, which can certainly be a compliance headache especially fix it’s an abandoned plan. There are plans on the books that are as obsolete as an 8 track like SAR-SEPa and Keogh plans, there may be money purchase plans that should have been merged into the employer’s paired plan when the cap on deductible contributions to a profit sharing plan was increased in 2002. There are just so many plans that you might have on the books that have fallen through the crack because the company sponsoring may no longer being around or you might have forgotten about it.

While brokers try to figure out which type of plan gets the IRA or ERISA disclosure, this maybe a good time for all plan providers to check the plans on their books and whether some plans may need their attention for one reason or another.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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