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3 pages. Excerpt: The DOL expressly noted that an intermediary cannot unilaterally invest the proceeds in its own proprietary investment funds without violating ERISA. However, the FAB appears to leave open the possibility that an intermediary can hold the funds in a proprietary investment vehicle with proper direction from a plan fiduciary....An intermediary may charge plans for the direct expenses incurred in connection with allocating the proceeds, but cannot unilaterally compensate itself.
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