Carroll Frank & Plotkin

Carroll Frank & Plotkin designs and negotiates the legal structure — selecting the carrier jurisdiction, drafting the separate-account provisions, and coordinating with the custodian and underlying fund managers. The insurance carrier issues the policy and provides the tax wrapper. Crucially, the firm's standard architecture stipulates that assets in the separate account are held by a third-party custodian, not the general account of the insurer, so a carrier insolvency does not entangle client assets.

Yes. Seth Plotkin has spoken publicly at industry events on the technical viability of placing digital assets inside PPLI separate accounts, a practice that many carriers have been slow to underwrite due to custody and valuation concerns. The firm works with custodial solutions that satisfy the regulatory requirements of the issuing jurisdiction while preserving the tax character of the wrapper. This has made the firm a reference point for crypto-founders and early-stage token investors seeking post-exit tax deferral without the self-custody risks of a non-insurance structure.

No. Carroll Frank & Plotkin does not provide investment management or advisory services. The policyholder retains full authority to direct the investments held in the separate account, subject to the investor-control rules that prevent the IRS from treating the policyholder as the direct owner of the underlying assets. The firm's value-add is delivering a compliant legal structure through which those investment decisions can be executed without triggering tax recognition, coordinating between the carrier, custodian, and fund managers to maintain the separation.

The firm has publicly confirmed structures holding hedge fund limited partnership interests, private equity fund commitments, direct private company stock, and cryptocurrency. The common constraint is that the asset must be capable of being held and valued within a custodial separate account that satisfies the carrier's and regulator's requirements. The firm works with families before a liquidity event to pre-position a policy so that assets can be contributed or purchased inside the wrapper without triggering a constructive-receipt test.

Because the firm's attorneys practice exclusively in PPLI/PPVA structuring — and do not sell, manage, or custody assets — they can negotiate policy terms on a flat-fee fiduciary basis, free from carrier exclusivity or production quotas. This often results in lower cost-of-insurance charges, more flexible investment guidelines, and carrier selection based on credit quality and regulatory posture rather than commission schedules. In practice, the model allows the client-side counsel to drive the underwriting process rather than receiving a pre-packaged policy.