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CD's as Securities


Hoard1

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Posted

Employer is converting from balance fwd valation to daily valuation. They have several CD's with prepayment penalties that will not come due until 12 months from now. Are the CD's considered Securities for purposes of the prohibitive transaction rules? If not, could the employer purchase them @ FMV from the Plan so that the Plan could be fully invested at date of transfer.

Posted

Yes, they are securities. DOL would likely issue a PTE on request, but that takes time and money. Why can't the daily valuation recordkeeper account for the CDs like a money market--fixed NAV and an interest accrual? I'd suggest this is more a recordkeeping weakness than anything else.

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Jon C. Chambers

Principal

Schultz Collins Lawson Chambers, Inc.

(415) 291-3004

Jon C. Chambers

Schultz Collins Lawson Chambers, Inc.

Investment Consultants

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