1. Purpose. To encourage collaboration between ROs(1)  and provide guidance on conducting these joint investigations of employee benefit plans and service providers.  Increasing collaboration among ROs can lead to:
    1. More efficient use of investigative talent and expertise;
    2. Increased consistency in applying enforcement policies;
    3. A better understanding of issues and trends affecting the regulated community on a national basis
  2. Case Characteristics. Cross-regional civil or criminal investigations are appropriate for one or more of the following:
    1. Large plans (i.e. plan asset or participant size);
    2. Service providers to multiple plan clients;
    3. Complex or systemic issues;
    4. Resource-intensive;
    5. Time-sensitive
  3. Ways to Collaborate. ROs can collaborate on cross-regional investigations by:
    1. Introducing investigations for consideration;
    2. Opening an Office 99, if appropriate;
    3. Leading an investigation involving another RO or OE staff;
    4. Participating in an investigation by providing investigative expertise or conducting a parallel investigation(2)   
  4.  Investigative Assistance/Auxiliary Investigations(3). When there is only the need for limited investigative activity on a case outside the geographic jurisdiction of the primary RO, the primary RO may:
    1. Request the RO having jurisdiction over this area (auxiliary office) to perform the work;
    2. Notify the auxiliary RO prior to conducting the work

    Appropriate examples of auxiliary investigations include:

    1. Issuance of an in-person subpoena requiring immediate production
    2. Conducting routine interviews
    3. Participating in search and seizures

Investigator/Auditors should charge time expended in auxiliary investigations to the primary RO’s case.


  1. Cross Regional investigations can also include the OE staff.
  2. The “lead region” designation is normally to be given to the RO that developed the investigation to the point of receiving cross-jurisdictional consideration.  However, other factors to consider include expertise needed to complete the investigation in an efficient and effective manner.
  3. Auxiliary investigations do not meet the criteria for cross-regional investigations.