Roberta J. Ufford

Practicing before the Labor Department, Roberta has addressed issues including the use of 12b-1 and similar fees paid by mutual funds, loans by service providers providing unitization services, and synthetic GICs.  She regularly assists plan fiduciaries and service providers with participant ERISA disclosure and prohibited transaction issues and with drafting, and negotiation of investment management, investment advice and recordkeeping and insurance agreements.

Two no-action letters from the SEC's Division of Market Regulation obtained by Roberta address whether recordkeepers and other service providers to participant-directed retirement plans are subject to regulation as broker-dealers under federal securities laws.  She also provides advice on how federal securities laws apply when employer securities are offered under plans, to non-qualified plans, and to commingled funds and other plan investment vehicles.

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