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September 8, 2012

Fred Reish Quoted in Advisor One

Los Angeles partner Fred Reish spoke to Advisor One about the Department of Labor's (DOL) guidance regarding asset allocation models under rules 408(b)2 and 404a-5.

Fred said he is concerned that advisors have misinterpreted the Employee Benefits Security Administration’s (EBSA) recently revised Field Assistance Bulletin (FAB) 2012-02, in coming to the conclusion that "asset allocation models (AAMs) can be offered to plans without the need to treat them as designated investment alternatives (DIAs) and, therefore, without the need to report the performance history, expense ratios, etc., of the AAMs."

Fred said that is not the case and “may inadvertently lead to problems under both the 408(b)(2) and 404a-5 regulations."

He provided a list of what he called "safe" answers for providing asset allocation models that will not be treated as DIAs.

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