Prohibited Transaction Exemption

[Guest jim williams]

Has anyone had any experience filing for a prohibited transaction individual exemption with the DOL? I have a client who wants to purchase a condo through his pension plan and then lease to his corporation as office space. He sponsors two plans- a floor offset db plan and a profit sharing plan. I believe because of the floor offset arrangement, the real property investment cannot be more than 10% of plan assets. I tried to convince him to take a profit sharing loan as an alternative, but he is insistent on trying for the DOL exemption.

On that note, who would qualify as a "qualified independent fiduciary"?

Any feedback would be appreciated.