---
title: "Build a file on party-in-interest dealings and the plan's investment duties"
url: "https://ailawframework.com/practice/superannuation/build-an-investment-strategy-and-related-party-dealing-file/united-states"
type: "task_jurisdiction_version"
site: "AI Law Framework"
id: "A27-A20260923-4-US"
practice_area: "Superannuation"
tier: "yellow"
lawyer_review: "required"
jurisdictions: ["US"]
last_reviewed: "2026-10-22"
---

# Build a file on party-in-interest dealings and the plan's investment duties

> List each proposed dealing, the other party, and whether the file says that party is a party in interest. Do not decide that an exemption applies.

Canonical page: https://ailawframework.com/practice/superannuation/build-an-investment-strategy-and-related-party-dealing-file/united-states  
Last reviewed: 2026-10-22

Site index for agents: https://ailawframework.com/llms.txt

## Key facts

| Fact | Value |
| --- | --- |
| Practice area | [Superannuation](https://ailawframework.com/practice/superannuation.md) |
| Human involvement | Yellow: Lawyer and AI draft together |
| How AI is used | List each proposed dealing, the other party, and whether the file says that party is a party in interest. Do not decide that an exemption applies. |
| What the lawyer must review | Except as section 1108 provides, 29 U.S.C. § 1106(a)(1) forbids a fiduciary who knows or should know the facts to cause the plan to sell, exchange or lease property with a party in interest, to lend to or borrow from a party in interest, to furnish goods, services or facilities with a party in interest, or to transfer or use plan assets for a party in interest. A transfer of property to the plan is treated as a sale or exchange under § 1106(c) if the plan assumes a mortgage or similar lien, or if a party in interest placed that lien within the 10 years ending on the transfer. Section 1106(b) forbids the fiduciary to deal with plan assets for the fiduciary's own account, to act for an adverse party, or to receive personal consideration from a party dealing with the plan. Section 1104(a)(1) still requires prudence and diversification. Section 1108 and section 1107 were not opened. Do not name an exemption or a percentage holding limit. You decide whether a dealing is prohibited and whether an exemption applies. |
| Written for | United States |
| Applies to | [Build an investment-strategy and related-party dealing file](https://ailawframework.com/practice/superannuation/build-an-investment-strategy-and-related-party-dealing-file.md) |

## Checking plan

- What the AI does: List each proposed dealing, the other party, and whether the file says that party is a party in interest. Do not decide that an exemption applies.
- Basis: Checked against the linked sources on 22 October 2026. Confirm the current instrument before reliance.

## Notes

- Do not name a class exemption or a QPAM exemption. Section 1108 was not opened.
- Employer securities and employer real property also sit under § 1106(a)(1)(E) and § 1107. Open § 1107 before you apply a limit.

## Sources

- [29 U.S.C. § 1106, Prohibited transactions](https://www.law.cornell.edu/uscode/text/29/1106) (checked 2026-10-22)
- [29 U.S.C. § 1104, Fiduciary duties](https://www.law.cornell.edu/uscode/text/29/1104) (checked 2026-10-22)
- [ABA Formal Opinion 512, Generative Artificial Intelligence Tools (29 July 2024)](https://www.americanbar.org/content/dam/aba/administrative/professional_responsibility/ethics-opinions/aba-formal-opinion-512.pdf) (checked 2026-10-22)

*Practice guidance for planning and review. Confirm current primary sources and the requirements of the actual matter. This is general information, not legal advice.*