Each calendar quarter, I post approximately 12 articles on my blog, fredreish.com. This quarterly digest provides links to the most popular posts during the past three months so that you can catch up on what you missed or re-read them.

• A Rollover Recommendation is a Securities Recommendation

  The Department of Labor (DOL) considers a rollover recommendation to be a recommendation to liquidate the investments in a participant’s 401(k) account or to transfer (and change) securities. This article discusses how the Securities and Exchange Commission, and the Financial Industry Regulatory Authority are in alignment with the DOL and why those agencies expect broker-dealers and investment advisers to have information about the investments held in a participant’s account.

• Discretionary Management of IRAs: Conflicts and Prohibited Transactions

  Where an investment adviser charges different fees for managing fixed income in a portfolio than for managing equities and has discretion to determine the allocation between the two in an IRA, the investment adviser has control over its fees, which appears to violate a prohibited transaction provision in the Internal Revenue Code. The inadvertent violation can be corrected, going forward, by using a blended rate where both allocations are charged the same fee. In other words, there would just be an account fee and not a fee that varied by allocations that are within the control of the investment adviser. This article focuses on allocations among asset classes where the adviser charges different fees.