The 404(a)(5) and 408(b)(2) fee disclosures has certainly been the topic of choice in the 401(k) ERISA world lately. The complexities of the disclosures have thrown a wrench into some plans in regards to disclosing the information.
Knowing that these are some of the major obstacles employers and employees are facing, C. H. Dean, Inc. recently held a seminar to better understand these disclosures and demonstrate how to handle frequently asked questions. The topics within the seminar included:
- What is Fee Disclosure?
- What items are required to be disclosed?
- How can C. H. Dean help you?
What is Fee Disclosure?
The 408(b)(2) disclosure rule exempts arrangements between service providers and plan sponsors from being treated as a prohibited transaction as long as the arrangement and compensation is reasonable. The required fee disclosures must be met in order for the arrangement to be deemed “reasonable”. The 404(a)(5) disclosures provide fee and investment related information intended to help participants make informed investment decisions.
What items are required to be disclosed?
408(b)(2) requires disclosure of the following three categoires to plan sponsors:
- Category 1 (Fiduciary or RIA) – Services provided, Fiduciary status, Compensation, and Investment information must be disclosed.
- Category 2 (Recordkeeping) – Platform record keeper, Direct & Indirect compensation, How compensation is paid, and Investment information
- Category 3 (Indirect Compensation) – Services, Identify payer of compensation, Description of arrangement between service provider and payer
404(a)(5) requires annual and quarterly disclosures to participants as follows:
- Annually – General plan information, Investment information, Administrative fees and expenses, and Participant-specific fees (explanation and amount charged)
- Quarterly – Amount of expenses, If revenue sharing is involved, Description of expenses, and Amount of individual expenses
How can C.H. Dean help you?
Our pension and investment consulting professionals develop and manage open architecture retirement plans for businesses and non-profit organizations. With decades of experience, we provide customized, one-stop solutions from plan evaluation and design, investment program development, and ongoing employee education, to retirement plan administration. As an independent firm dedicated to maintaining integrity in our practices and processes, we act only to advance your interests. Our highly trained and skilled team will analyze your current situation and evaluate your future needs to customize a program that achieves your goals and reflects your values.
- Independent and open architecture platform
- Actively managed model investment portfolios for every participant
- Hassle-free plan conversion
- Responsive and dedicated local service team
- Consistent, risk adjusted investment returns
- Daily valuation and segregated investment accounting
- Ongoing participant education
- Wealth management solutions for plan participants at any level of employment
- Personalized participant investment performance report