SD IRAs & the DOL Fiduciary Rule for private equity fund managers

[Bob Malecki]

Mat Sorensen posted a good article at the link below, and implies that a manager of a Reg D fund might be considered a fiduciary if you run a private fund, or a start-up, or a real estate partnership and if you take investment dollars from a retirement account.  He considers that the DOL definition may include the fund sponsor as a fiduciary since the investment docs (PPM, or other) will likely contain information that would be considered “investment advice” and since the manger/sponsor will indirectly be receiving compensation as a part of management of the fund or start-up then the managers are indirectly receiving a fee for providing investment advice and consequently you may be deemed a fiduciary.

Does anyone here have an opinion on this in agreement or to the contrary? 

https://sdirahandbook.com/self-directed-iras-dol-f...