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RAUM - 4o1(k) held away assets

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Mar 14, 2017 3:56 pm

Do you count 401(k) held away plan assets as “Assets Under Advisement” and separate them from your organization’s RAUM? Or, do you count them in your RAUM, contending that you provide “continuous and regular management” of those assets?

Jan 19, 2018 5:04 pm

If these are 3(38) or 3(21) assets, you are permitted to count them as long as you are providing "continuous and regular management."