• An RIA that charged an advisory fee to its own 401(k) plan;
  • An affiliate of an RIA that received 12b-1 fees and other revenue based on investment recommendations that the RIA made to a 401(k) plan;
  • An RIA and a third-party administrator (TPA) that were owned by a common parent, but went afoul of fiduciary regs when the TPA administered the RIA’s plan for a fee;
  • An affiliate of an IRA that was a sub-advisor to Collective Investment Funds (CIFs). The RIA, acting as a fiduciary advisor to plans, recommended the CIFs to retirement plans.
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