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Prohibited Transactions


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Guest allanH
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We have a client that is a Professional Employer Organization (PEO). The PEO sponsors a 401(k) Plan that is funded entirely with employee contributions. The PEO charges its clients a fee for the activities associated with the 401(k) Plan including the processing of payroll deductions and remittances to the full-service, turnkey provider. The PEO now wants to receive all or a part of the commissions generated by the mutual funds in the Plan. Ignoring any licensing issues for a minute, it seems to me that this would constitute a prohibited transaction and would be a breach of the "exclusive benefit" rule. Any comments?

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