Series 66 Quiz
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CLIENT INVESTMENT RECOMMENDATIONS AND STRATEGIES
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A manufacturing company hires a financial planner, an IAR of a state-registered investment adviser, for a discrete project: recommending an investment menu for the company's new 401(k) plan. The engagement letter states that the plan's investment committee will treat the recommendations as the primary basis for its fund selections, and the recommendations are tailored to the company's workforce. The planner completes the recommendations in six weeks, receives a flat $15,000 fee from the company's operating account, and retains no ongoing role: the committee will make all future decisions, and the planner will not monitor the menu or provide further advice.
Under ERISA, is the financial planner a fiduciary with respect to the plan?
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