Self-Directed Investments

If your IRA or Qualified Retirement Plan loans funds to certain family members, such as lineal descendants and spouses of lineal descendants, or an entity that you or certain family members own or control, whether controlled individually or as an officer of a corporate general partner, managing member, etc., the transaction could possibly be a prohibited transaction under the Internal Revenue Code Section 4975. Our policy on this issue is that if you or another disqualified person is an officer or director of an entity, or an officer of a corporate general partner, managing member, etc., and you will collectively own less than 50% of the entity, then you will need to obtain a legal opinion from an ERISA or tax attorney addressed to you in which the transaction is discussed in detail prior to us processing your investment instructions. If you, any family member, or disqualified persons collectively will own 50% or more of the entity, we will not process the investment even if you are able to obtain a legal opinion.