fb-roll-0001
{
"arrangement": "A broker-dealer (a Financial Institution relying on PTE 2020-02) recommends that a Retirement Investor roll her $480,000 401(k) balance into an IRA at the firm.",
"stipulated_facts": [
"The written fiduciary acknowledgment and the written description of services and material Conflicts of Interest were provided before the recommendation.",
"The recommendation reflected the investor's objectives, risk tolerance, financial circumstances, and needs; compensation is reasonable and no misleading statements were made.",
"Neither the Investment Professional nor the Financial Institution ever documented the specific reasons the rollover was in the investor's Best Interest — nothing was recorded before or after the rollover executed.",
"The firm's policies, procedures, and retrospective review are otherwise in place and timely."
]
}Judged only against the PTE 2020-02 conditions quoted in this item's sources, which conclusion follows about this arrangement? Answer with exactly one option id.
satisfies-conditions— The stipulated facts satisfy the quoted conditionsfails-rollover-documentation— It fails the rollover-documentation condition (Section II(c)(3))fails-fiduciary-acknowledgment— It fails the written fiduciary-acknowledgment condition (Section II(b)(1))fails-retrospective-review-timing— It fails the retrospective-review timing condition (Section II(d)(4))
fails-rollover-documentation
Section II(c)(3) requires the Financial Institution to document the specific reasons that any recommendation to roll over assets from a Plan to another Plan or an IRA is in the Best Interest of the Retirement Investor. The stipulated facts state that no such documentation was ever created. Acknowledgment, disclosure, conduct standards, and review timing are stipulated satisfied, so the other failure options are not the breached conditions.
Selects fails-rollover-documentation, anchored to II(c)(3).
“documents the specific reasons that any recommendation to roll over assets from a Plan to another Plan or an IRA”
Each quoted passage is exact-matched, after typographic normalization, against the corpus text fetched from the issuing authority (hashes in the corpus manifest). An item whose quote stops matching fails the build.
“The Financial Institution documents the specific reasons that any recommendation to roll over assets from a Plan to another Plan or an IRA” — dol-pte-2020-02
The key correctly identifies that the arrangement fails the rollover-documentation condition. Section II(c)(3) explicitly requires the Financial Institution to document the specific reasons that a rollover recommendation is in the Best Interest of the Retirement Investor. Since the stipulated facts state that no such documentation was ever created, the arrangement fails this condition.
“documents the specific reasons that any” — dol-pte-2020-02
The stipulated facts state that neither the Investment Professional nor the Financial Institution ever documented the specific reasons the rollover was in the investor's Best Interest. Section II(c)(3) requires: 'The Financial Institution documents the specific reasons that any recommendation to roll over assets from a Plan to another Plan or an IRA... is in the Best Interest of the Retirement Investor.' Therefore the arrangement fails the rollover-documentation condition. The other conditions are stipulated satisfied, so the other failure options are not correct.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.