fb-roll-0004
{
"arrangement": "A Financial Institution relying on PTE 2020-02 recommends rolling a $310,000 401(k) into an IRA at the firm.",
"stipulated_facts": [
"Before the transaction, the investor received: a written fiduciary acknowledgment; a written, accurate description of services and material Conflicts of Interest; and written documentation of the specific reasons the rollover is in her Best Interest, comparing the plan's and IRA's investments, fees, and services against her objectives, risk tolerance, financial circumstances, and needs.",
"The advice reflected those factors and did not place the firm's interests ahead of hers; compensation is reasonable; the Financial Institution and Investment Professional sought to obtain the best execution of the transaction reasonably available under the circumstances, as required by the federal securities laws; and no statement made was materially misleading.",
"The firm maintains the required policies and procedures and completed its annual retrospective review, report, and certification four months after the review period ended."
]
}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-retrospective-review-timing— It fails the retrospective-review timing condition (Section II(d)(4))fails-best-interest— It fails the Best Interest standard (Section II(a)(1))
satisfies-conditions
Each quoted condition is satisfied on the stipulated facts: the rollover reasons were documented and delivered before the transaction; the written acknowledgment and conflicts description were provided; every element of the Impartial Conduct Standards — best interest, reasonable compensation, best execution, and no materially misleading statements — is stipulated met; and the retrospective review completed four months after the period end, within the six-month deadline the quoted II(d)(4) sets. A conditions checklist can and here does come back clean.
Selects satisfies-conditions; four months is inside the six-month deadline.
“The review, report and certification are completed no later than six months following the end of the period covered by the review”
“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 review, report and certification are completed no later than six months following the end of the period covered by the review.” — dol-pte-2020-02
The answer key correctly concludes that the arrangement satisfies the conditions. The stipulated facts explicitly confirm that the rollover documentation was provided before the transaction, the Impartial Conduct Standards (including Best Interest, reasonable compensation, best execution, and no misleading statements) were met, and the retrospective review was completed four months after the period ended, which complies with the six-month deadline set forth in Section II(d)(4).
“The review, report and certification are completed no later than six months following the end of the period covered by the review.” — dol-pte-2020-02
The stipulated facts place completion of the annual retrospective review, report, and certification four months after the review period ended, which is within the six-month deadline in Section II(d)(4). The facts also state that before the transaction the investor received the written fiduciary acknowledgment, accurate services/conflicts description, and written documentation of specific rollover reasons comparing plan/IRA investments, fees, and services against her objectives, risk tolerance, financial circumstances, and needs, satisfying Section II(c)(3) and II(b)(3). The Impartial Conduct Standards elements are also stipulated met. Therefore 'satisfies-conditions' follows.
v1; no errata. Demonstrate a key error and the correction is published here, credited — challenge policy.