Oversight and monitoring are key plan governance activities. ERISA provides that a person is a fiduciary to the extent he exercises any discretionary control respecting the management of the plan or exercises an authority or control respecting management or dispositions of its assets or he has any discretionary responsibility in the administration of the plan. […]
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 disclosure403(b) Plans Part III – Gathering the data You need an audit – what you can expect This ErisaALERT is the third in a series covering issues facing 403(b) plan sponsors. Our first in the series discussed the rules regarding who is subject to an audit as well as tools available to help you select […]
403b403(b) Plans Part II – what can you expect from your auditor You need an audit – what you can expect This ErisaALERT is the second in a series covering issues facing 403(b) plan sponsors. Our first in the series discussed the rules regarding who is subject to an audit as well as tools available […]
403b, audit, auditorDecember, 2007 DOL Auditing Medical Plan The Department of Labor (DOL) is starting to audit health plans!!! We are currently working with a client in responding to a DOL audit notice. Relying on that old adage “forewarned is forearmed”, we would like to share with you the data that the DOL is requesting in this […]
DOL, DOL audits, DOL plan audits, H&W plan auditsYou 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 FeesIn 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 disclosuresSeptember, 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 contractJanuary, 2007 DOL Issues Guidance on Periodic Benefit Statements WHAT IS IT?: – In December 2006, the DOL issued Field Assistance Bulletin (FAB) No. 2006-03 regarding the periodic benefit statement requirement contained in the Pension Protection Act of 2006 (PPA). Plan sponsors should act in good faith compliance until regulations are issued concerning the pension […]
benefit statements, DOL, FAB 2006-03, periodic benefit statementsThe IRS issued Notice 2020-76 which once again extends the due date for certain information returns under IRC6055 and 6066. A brief recap of the filing requirements: Due date Extended due date Forms 1095-C and 1095-B Statements to Individuals February 1, 2021 March 2, 2021 Submission to the IRS February 28, 2021(paper)March 31, 2021 (iffiled […]
6056, ACA, compliance; 6055, Disclosure, Reporting(c) 2015 Erisa Diagnostics - We focus on benefits, so you can focus on business