We have developed a Participant Disclosure checklist to help you with the fee related participant disclosures. Just click on the download link. Participants and beneficiaries (participants) in participant directed individual account plans (except SEPs, IRAs, SIMPLEs and governmental plans are subject to the ERISA §404(a)(5) disclosures. The special rules applicable to Company stock are not […]
ErisaALERT 2010-12 Disclosures Participant Directed Individal Account Plans
In 2008, we issued a series of ErisaALERTs discussing the proposed regulations regarding fee transparency (Plan participants, Reasonable Contract, 2009 Schedule C). The Obama administration delayed finalization of the regulations pending review. In July 2010 we issued an ErisaALERT discussing the Reasonable Contract interim final regulations. In this ErisaALERT, we will cover the final regulation […]
404(a)(5), defined contribution, ERISA, participant disclosureErisaALERT 2008-02 Fee Transparency Part 1 – Disclosures to Plan Participants
August, 2008 Fee Transparency Part 1 – Disclosures to Plan Participants There are three pieces of DOL guidance that Plan Sponsors should have on their list of “to dos”. Two are in the form of proposed guidance with the third in final form. Why should you have this on your “to do” list? Because they […]
408b2, Fee Transparency, Participant disclosuresErisaALERT 2015-02 IRC 408b2 disclosures on the horizon for health and welfare
408(b)(2) disclosures for retirement plans have been in effect for a few years. It is important to remember that the final regulations reserved a section for welfare plan disclosure. The preamble to the final regulations noted that commenters to the regulations supported disclosures specifically tailored to welfare plans. Although somewhat dated, the Employee Benefits Security […]
401k, 401k fees, fee disclosure, Form 5500, health & welfareErisaALERT 2012-14 Covered 408 (b) Service Provider Fee Disclosures
You received your 408(b)(2) disclosures from your covered service providers. Have you looked at them? Do you know what you are looking at? Do you know what you are supposed to do next?
In this ALERT we will focus on the plan sponsor’s responsibility with respect to the covered service provider (CSP) fee disclosures. MORE
2012 archive, 408 (b) (2), Disclosure, DOL, Fee Transparency, Plan FeesErisaALERT 2012-12 ERISA Participant Fee Discolsures
In this ALERT we will focus on the plan sponsor’s responsibility to provide fee disclosures to participants in participant directed individual account plans (except SEPs, IRAs, SIMPLEs and governmental plans) by August 31st. The ball is now in the plan sponsor’s court and it is getting close to the end of the overtime period We […]
2012 archive, 404(a)(5), Disclosure, Participant disclosuresErisaALERT 2011-17 IRS revises Interim Policy on Electronic Disclosures
Snapshot In ErisaALERT 2011-13, we discussed Technical Release 2011-03, an interim enforcement policy regarding electronic delivery of the required participant disclosures until further guidance becomes available. Technical Release was intended to provide guidance related to DOL regulations issued in October 2010 regarding disclosures for participant directed accounts. The participant disclosures are plan related and investment […]
Disclosure, electronic disclosure, ERISA, IRSErisaALERT 2011-13 Interim Policy on Electronic Disclosures
Snapshot In October 2010, the DOL issued regulations regarding disclosures (referred to as “participant disclosures” in this ErisaALERT) in participant directed accounts. The participant disclosures are plan related and investment related with each category requiring certain expense related disclosures. Certain participant disclosures can be provided in the summary plan description and/or the pension benefit statement […]
Disclosure, DOL, interim policy on electronic disclosuresErisaALERT 2010-11 Reasonable Contract ERISA 408(b)(2) disclosure requirements
Reasonable Contract under ERISA 408(b)(2) Disclosure Requirements In 2008, we issued a series of ErisaALERTs discussing the proposed regulations regarding fee transparency (Plan participants, Reasonable Contract, 2009 Schedule C). The Obama administration delayed finalization of the regulations pending the new administration’s review. The wait is over; interim final regulations regarding the Reasonable Contract were issued […]
408b2, Disclosure, ERISA, reasonable contractErisaALERT 2008-03 Fee Transparency Part 2 – Reasonable Contract or Arrangement Under Section 408(b) (2) – Fee Disclosure
September, 2008 Fee Transparency Part 2 – Reasonable Contract or Arrangement Under Section 408(b) (2)—Fee Disclosure As noted in Part 1 of our three part Fee Transparency series, there are three pieces of DOL guidance that Plan Sponsors should have on their list of “to dos”. Two are in the form of proposed guidance with […]
408b2, Fee Transparency, reasonable contract