Advisory Opinion 2018-01

There is a difficulty, which is inherent to bulk IRA programs: IRAs are individually owned investment contracts, which are under the control of the former participant-even though they are set up by the former employer. Using negative consent triggers fiduciary status. This also demonstrates that there is a whole range of other laws which come into play when dealing with IRAs. 
Continue Reading DOL RCH Advisory Opinion Illustrates the Difficulties Inherent to Bulk IRA/Auto Portability Programs