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Fiduciary Guidance Counsel
If one wants the "PPA" statutory prohibited-transactions exemption for an eligible investment advice arrangement, ERISA 408(g)(5) requires an annual compliance audit on whether the arrangement meets the conditions of ERISA 408(g), and requires that the independent compliance auditor's written report be issued to the independent fiduciary who approved the plan's use of the arrangement.

Has anyone seen such a report? Is anyone in America doing this?
Fiduciary Guidance Counsel
In the words of the dull teacher in the Ferris Bueller movie: anyone? anyone?
snappy
QUOTE (Fiduciary Guidance Counsel @ Jun 5 2009, 02:22 PM) *
In the words of the dull teacher in the Ferris Bueller movie: anyone? anyone?



My sense is that no one is doing any of the PPA investment advice stuff because it is so, so in flux. Seems like any expense on that could easily be money down the drain, and there is even less appetite for that than usual these days. FWIW.
Fiduciary Guidance Counsel
snappy, thank you for your observation!

It mostly confirms what I've suspected: An adviser that could most benefit from the new statutory exemption is one that can't exempt its intended service under pre-2006 law. But such an adviser isn't eager to develop a service until the law changes or enjoys an interpretation that's no longer controversial.
PPAFiduciaryAdviser
Hi Peter,

In writing a blog post, I just ran across your question. You and snappy are mostly correct, as we have found that our operating as a PPA Fiduciary Adviser is extremely rare, but we have done so since we were certified by CEFEX. CEFEX and DALBAR are the only organization doing the EIAA audit that I am aware of, due to the minimal number of groups operating in such a capacity. Operating through CEFEX, our auditor is Roland|Criss out of TX. We have now gone through 3 audits since being the 1st company in the nation to complete the CEFEX Fiduciary Adviser (PPA) certification. Let me know if I can be of service as it relates to you question or interest in the PPA Fiduciary Adviser safe harbor.

Best,

Chad Griffeth
BeManaged
http://bemanagednow.com
cgriffeth@myactium.com
P: (616) 871-0751

QUOTE (Fiduciary Guidance Counsel @ Jun 18 2009, 05:12 PM) *
snappy, thank you for your observation!

It mostly confirms what I've suspected: An adviser that could most benefit from the new statutory exemption is one that can't exempt its intended service under pre-2006 law. But such an adviser isn't eager to develop a service until the law changes or enjoys an interpretation that's no longer controversial.

mbozek
QUOTE (PPAFiduciaryAdviser @ Jul 22 2010, 11:18 AM) *
Hi Peter,

In writing a blog post, I just ran across your question. You and snappy are mostly correct, as we have found that our operating as a PPA Fiduciary Adviser is extremely rare, but we have done so since we were certified by CEFEX. CEFEX and DALBAR are the only organization doing the EIAA audit that I am aware of, due to the minimal number of groups operating in such a capacity. Operating through CEFEX, our auditor is Roland|Criss out of TX. We have now gone through 3 audits since being the 1st company in the nation to complete the CEFEX Fiduciary Adviser (PPA) certification. Let me know if I can be of service as it relates to you question or interest in the PPA Fiduciary Adviser safe harbor.

Best,

Chad Griffeth
BeManaged
http://bemanagednow.com
cgriffeth@myactium.com
P: (616) 871-0751

[


How much do you charge for an audit?
PPAFiduciaryAdviser
We provide the advice, while a CEFEX auditor provides the audit. The firm that performs the function is Roland|Criss out of TX.

QUOTE (mbozek @ Jul 22 2010, 10:33 AM) *
QUOTE (PPAFiduciaryAdviser @ Jul 22 2010, 11:18 AM) *
Hi Peter,

In writing a blog post, I just ran across your question. You and snappy are mostly correct, as we have found that our operating as a PPA Fiduciary Adviser is extremely rare, but we have done so since we were certified by CEFEX. CEFEX and DALBAR are the only organization doing the EIAA audit that I am aware of, due to the minimal number of groups operating in such a capacity. Operating through CEFEX, our auditor is Roland|Criss out of TX. We have now gone through 3 audits since being the 1st company in the nation to complete the CEFEX Fiduciary Adviser (PPA) certification. Let me know if I can be of service as it relates to you question or interest in the PPA Fiduciary Adviser safe harbor.

Best,

Chad Griffeth
BeManaged
http://bemanagednow.com
cgriffeth@myactium.com
P: (616) 871-0751

[


How much do you charge for an audit?

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