This Investment Policy Statement ("IPS") is intended to assist the Committee in making investment-related decisions in a prudent manner. Managers shall exercise prudent person standards in defining prohibited investments.According to Rule 204A1 of the Advisers Act, investment advisers must establish, maintain and enforce a Code of Ethics. ERISA, they are subject to parallel prohibited transaction rules in the Internal Revenue Code. Other state securities regulatory authorities require an ERA to register as an investment adviser and file a complete Form ADV. IRA rollover advice specifically covered. ERISA's Fiduciary "Investment Advice" Rules ; Massachusetts. Proposed Regulations – Fiduciary Conduct Standard. Collazo, Senior Benefits Advisor. Do you need a financial advisor for your retirement plan?