Focus on . . . Prohibited Transactions, Part II

Abstract

This is Part II of a two-part article. Part I discussed the definition of party in interest, categories of prohibited transactions, and statutory exemptions under ERISA. Part II covers regulatory exemptions, the excise tax on prohibited transactions, the special rules for employer securities and real property, the Voluntary Fiduciary Correction Program (VFCP) and qualification issues, and concludes with recommendations for changes to the rules.

Keywords: regulatory exemptions, excise tax, prohibited transactions, employer securities, Voluntary Fiduciary Correction Program