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Cetera Supervision recently confirmed that any and all rollovers from an employer-sponsored plan into an IRA require the Rollover Recommendation report to be created in the BIC tool. The Rollover Recommendation report should be completed at or prior to the recommendation to roll over the plan.
Unique Situations:
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Death claim from a deceased person’s employer- sponsored plan. Example: A client rolls over his deceased spouse’s 401k into his own IRA. This requires the Rollover Recommendation report to be created in the BIC tool.
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QDRO: A Qualified Domestic Relations Order (QDRO) instructs that all or a portion of one spouse’s employer-sponsored plan be rolled over into the other spouse’s IRA. This requires the Rollover Recommendation report to be created in the BIC tool.
Employer-sponsored plans include the following: 401(k), 457, 403(b), TSA, and pension plans.
What does “recommendation” mean? If you engage in any discussion with the client regarding the rollover, or if you help process any of the paperwork for the rollover, it is considered a “recommendation.”
Note: Cetera Supervision recently issued a Letter of Education to an advisor for not completing the Rollover Recommendation report for a death claim rollover to move a deceased spouse’s 401k into their client’s IRA.
Please reach out to the Prosperity Network OSJ Compliance team with any questions. 913-529-5500 Option 2. compliance@prosperityadvisors.com.
Internal Use Only
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