Samuel W. Halpern, executive vice president of Independent Fiduciary Services, Washington, recalled testifying before a working group of the ERISA Advisory council in the mid-1990’s that investment consultants should be regarded as fiduciaries. At that time he indicated, “And to the extent they are, they (consultants), should be subject to the self-dealing provisions of (ERISA) where they should not be paid by someone with an interest that is adverse to the plan.” He still maintains this view. Mr.