Many of you know of me as being well versed in 403(b) matters; others are familiar with my work in annuities; others still consider my familiarity with MEPS or ERISA broker dealer issues. But the heart and soul of my practice over the past nearly 30 years has really been the fiduciary rules-in particular, the
Prohibited Transaction
ERISA Plans’ Ultimate-and Criminal-“Prohibited Transaction” Rule of 18 USC 1954
By Robert Toth on
Posted in Complex Prohibited Transactions
Lurking darkly in the background behind all the recent discussions of fee disclosure and how the prohibited transaction rules apply under 408(b)(2), is something most of us in the benefits world typically pay little attention to: the U.S. Criminal Code.
We all have a general knowledge that kickbacks and racketeering schemes of any sort are…