David J. Passey

Final Fee Disclosure Rules for Service Providers to Pension Plans: Department of Labor Regulations Modify Fee Disclosure Rules for Service Providers to Pension Plans
Rebecca S. Coccaro,Jeffrey D. Hochberg,Malcolm S. Hochenberg,Andrew S. Mason,David J. Passey,Marc R. Trevino, February 24, 2012
The Department of Labor recently issued final fee disclosure regulations for service providers to pension plans, 401(k) plans and other similar arrangements (the “Final Regulations”). The Final Regulations in large part adopt the interim final regulations issued by the Department of...

IRS Announcement Provides Temporary Relief to IRA Owners; DOL Considering Additional Relief: IRS Announcement Forestalls Disqualification of Many IRAs, Pending Further DOL Consideration of Additional Relief, Including Potential Class Exemption
Jeffrey D. Hochberg,Malcolm S. Hochenberg,Andrew S. Mason,David J. Passey,Max J. Schwartz,Frederick Wertheim, December 14, 2011
Today, in Announcement 2011-81 (the “IRS Announcement”), the Internal Revenue Service (the “IRS”) provided temporary relief to IRA owners from the recently issued Department of Labor (“DOL”) Advisory Opinion 2011-09A (the “DOL Opinion”).

DOL Advisory Opinion Has Potential to Adversely Impact IRA Owners: Common Indemnification and Security Arrangements Could Cause IRAs to Lose Their Tax-Exempt Status
Jeffrey D. Hochberg,Malcolm S. Hochenberg,David J. Passey,Max J. Schwartz,Frederick Wertheim, December 7, 2011
In Advisory Opinion 2011-09A (the “DOL Opinion”), released to the public on November 29, 2011, the Department of Labor (the “DOL”) opined that common indemnification arrangements covering IRA brokerage accounts are not permitted under Prohibited Transaction Exemption 80-26...