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prohibited transaction?


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We have a plan that the employer wants the broker to perform the following actions for the plan:

Transferring funds over the internet. (The participants give them their PIN and he makes the transfers.)

Receives contributions from multiple locations, consolidates them, and sends one wire.

Sign distribution forms as the plan representative.

Receive all correspondence that we would normally send to the plan, including nondiscrim results, statements, and 5500 reporting.

These are in addition to the normal investment advisor functions he performs for the plan.

Is he disqualified and would these be prohibited transactions?

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