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Advisor Considerations for Rollover Discussions (PDF)
Retirement Learning Center, LLC 
Oct. 26, 2014
"[DOL] Advisory Opinion 2005-23A specifies that if a financial advisor is not already a plan fiduciary, then making distribution or rollover recommendations to plan participants WOULD NOT make the advisor a fiduciary, even if investment recommendations are included. However, if a financial advisor is already a plan fiduciary, then making distribution or rollover recommendations to plan participants WOULD subject such recommendations to a fiduciary standard and, therefore, could give rise to conflicts of interest and, potentially, prohibited transactions."
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