This Sample WSP/CoE Section – IRA Rollover Recommendations is a sample written supervisory procedure (also referred to as a compliance manual section) intended for an investment adviser firm which may recommend to a client the rollover of retirement plan assets to individual retirement account (IRA).
This sample investment adviser compliance manual section for IRA rollovers has been updated in light of the U.S. Department of Labor’s PTE 2020-02 and covers an investment adviser’s fiduciary standard of conduct, certain requirements of the of the DoL’s prohibited transaction exemption, and the impartial conduct standards, conflicts of interest disclosures and investment adviser representative’s responsibilities related to the recommendation of a IRA rollover. Additionally, this sample compliance manual section provides an example of supervisory procedures associated with such IRA rollover recommendations.
Included with Value, Bronze, Silver, Gold and Platinum Packages. Last updated in May 2021.
IRA Rollover Compliance Under PTE 2020-02 – February 24, 2022
IRA Rollovers Under U.S. Department of Labor’s PTE 2020-02 – October 28, 2021
DOL Clarifies Fiduciary Advice Exemption for IRA Rollovers – May 9, 2021
Updated Sample Form – Suitability – Retirement Plan Rollover – Client Acknowledgement – May 5, 2021
Form ADV – Sample Language – Rollover Recommendation – April 16, 2021
OMB Approves Request for DoL Fiduciary Rule Delay – August 31, 2017
DoL Proposes Fiduciary Rule Delay – August 11, 2017
Department of Labor Fiduciary Rule – August FAQs – August 09, 2017
This sample document is merely an example for general reference and educational purposes. RIA Compliance Consultants, Inc. is providing this sample document to the purchaser on an “as is” basis with no warranty or guaranty whatsoever.
This sample document should be considered a starting point, and purchaser should not treat this sample document as a final document ready for use. The sample document has not been customized to the purchaser’s business model, the specific investment advisory rules applicable to the purchaser’s investment adviser or the written supervisory procedures and code of ethics of purchaser’s investment adviser.
This sample document may not be applicable or appropriate for every investment adviser. The purchaser should not consider a sample document purchased from our online store as an exhaustive, comprehensive or definitive list of the items necessary to meet the purchaser’s obligations under the applicable investment adviser laws and rules.
This sample document is not intended to detect or prevent fraud, selling away, Ponzi schemes, undisclosed outside business activities, inaccurate or false fee calculations, theft, misappropriation or unlawful conversion of client funds.
Due to changes of investment adviser laws and rules, this sample documented may become outdated and need to be updated or discontinued. RIA Compliance Consultants, Inc. will not be providing any subsequent updates of this sample documents to the purchaser. Likewise, RIA Compliance Consultants, Inc. will not be monitoring and reporting to the purchaser any issues related to the use of this sample document.
Since this sample document may not reflect the specific investment advisory requirements of the purchaser’s securities regulator, the purchaser should check with the securities regulator(s) with jurisdiction over its investment adviser or review any applicable rules before using this document.
This sample document is not a substitute for retaining a compliance professional to advise and assist the purchaser regarding its investment adviser’s compliance program. Unless otherwise agreed to in writing, the purchaser understands that the purchaser has not engaged RIA Compliance Consultants, Inc. in a consulting relationship by merely purchasing or utilizing a sample form. Additionally, the purchaser understand that unless otherwise agreed to in writing, RIA Compliance Consultants, Inc. is not responsible for customizing this sample document, updating the sample document, preparing the purchaser’s written supervisory procedures or code of ethics, or notifying the purchaser of changes to the investment adviser laws and rules.
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If this product involves the purchase of a WSP/CoE update section on a la cart basis (not part of an annual compliance program engagement), the purchaser will have three ways to access this sample document: 1) Following payment, the purchaser will be redirected to a thank you page with a button to download the sample document; 2) The purchaser will receive an invoice email with a link to download the sample document; 3) If the purchaser has an account or elects to create one at the time of checkout, this sample document can be accessed from the “Downloads” section of purchaser’s My Account page. The purchaser will have 90 days to download sample document, which is limited to 3 downloads during this period.
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To the extent that your investment adviser firm currently has an active Annual Compliance Program (“ACP”) engagement with RIA Compliance Consultants, Inc., this sample document may be available as part of that engagement depending upon your firm’s ACP package (e.g., Bronze, Silver, Gold, Platinum and Titanium). Please refer to the “Description” tab within the product to determine whether the sample document is included as part of your firm’s ACP package. If included and your firm (via the individual making payments in our system) has designated you as a team member in our Knowledge Base, please log into our Knowledge Base to download the sample document. (For detailed instructions on how to access the Knowledge Base, please refer to the following webpage: Knowledge Base Instructions.) If not included in your ACP package, you can make an a la carte purchase of the sample document through this product in our online store.
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