b'This model probably doesnt work if you are trying to acquire property directly as someone will have to take an active role in managing it on behalf of the group (turning it into a passive investment for them), which would be better operated as a syndicate.Caution Regarding Retirement Fund Investors TheEmploymentRetirementSecurityActof1974(ERISA), DepartmentofLaborRegulationsstatethat,unlessexempt,whena retirementplan(whetherself-directedornot)ownstwenty-fivepercent (25%) or more of the total value of the interests sold in a company, the interests may be deemed a plan asset. Once deemed plan assets, the issuer becomes subject to ERISA fiduciary rules, and additional regulation and reporting requirementswhich is not something you want to trigger. In many cases an investment club will invest in securities in others offerings, versus directly owning real estate. In those cases, the interests offered by the investment club are NOT exempt from constituting a plan asset under the real estate operating company (REOC) exemption. This exemption is only available when at least fifty percent (50%) of the assets owned and operated by the issuer are directly owned real estate assets. What does this mean for investment clubs? There is a 25% limit on the percentage interests of an investment club that may be raised from pension plan investors (such as self-directed individual retirement accounts or 401k plans,orpensionplans).Makesureyoukeeptrackofthepercentage interests owned by your pension fund investors and dont exceed this limit. 151'