Earl Posted February 21, 2014 Posted February 21, 2014 Would a plan of a CFP (Certified Financial Planner) be covered by the PBGC? Seems to fit the list in ERISA § 4021(c )(2)(B) but not explicitly. Any opinions or experiences? Thank you CBW
Peter Gulia Posted February 21, 2014 Posted February 21, 2014 Your query turns, in part, on whether the decision-maker considers a holder of the CFP certification mark to be a "professional individual" within the meaning of ERISA 4021©(2)(B). Given that text, a range of statutory-interpretation arguments might be possible. Consider suggesting that your client get its lawyer's advice about whether it makes sense to seek a PBGC opinion letter, or to rely on a lawyer's written opinion. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
Rball4 Posted February 21, 2014 Posted February 21, 2014 In my experience the client would need to be covered by the PBGC, but it's a gray area.
david rigby Posted February 21, 2014 Posted February 21, 2014 Just a guess: the PBGC has probably answered this exact question before. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
Earl Posted April 4, 2014 Author Posted April 4, 2014 Took them about 5 weeks and they said "covered." CBW
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now