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Discretionary Management of IRAs: Conflicts and Prohibited Transactions
FredReish.com Link to more items from this source
[Guidance Overview]
Dec. 20, 2022

"Where an investment adviser charges different fees for managing fixed income in a portfolio than for managing equities, and has discretion to determine the allocation between the two in an IRA, the investment adviser has control over its fees, which appears to violate a prohibited transaction provision in the Internal Revenue Code. The inadvertent violation can be corrected, going forward, by using a blended rate where both allocations are charged the same fee.... There are other potential solutions, including transitioning the allocations to nondiscretionary advice."

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