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Investment Adviser Fees


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Is it proper for an investment adviser to a multiemployer pension fund to collect an annual fee from the fund while receiving commissions on sales to the fund? The investment adviser, in this situation, has a broker dealer license with the company that is paying the adviser commissions for sales. I know that the SEC allows for the receipt of both an annual fee and commissions in the event the adviser has a broker dealer license, but does this situation violate ERISA in any way?

Thank you in advance for your help and guidance.

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