The DOL’s Focus on Conflicts of Interest (Part 1): Householding Accounts and Recommending Affiliate Funds

In an article for Journal of Pension Benefits, benefits and executive compensation partners Fred Reish and Joshua Waldbesser and counsel Joan Neri discuss the conflict-of-interest issues that arise under the prohibited transaction rule under ERISA and the Internal Revenue Code known as the self-dealing rule.

The co-authors deliberate self-dealing and how it can arise in a number of circumstances, including through householding accounts and recommending affiliate funds. The article emphasizes that advisers should examine their fee practices and procedures in connection with aggregating a client’s personal and retirement accounts to ensure that it will not result in a self-dealing transaction for the client.