Participant Fee Disclosure-Q & As
Two helpful Question & Answers (Q&A) Technical Update columns are now available on the SunGardRelius website: "DOL Broadens Electronic Participant Fee Disclosure" and "Quarterly Benefit Statement and the Partcipant Fee Disclosure Regulations." Click on the titles to learn the answers to these timely questions.
- What are the DOL's general policies on electronic disclosure of information to participants?
- What are the DOL's policies on electronic disclosure of quarterly benefit statements?
- If a plan distributes the new plan and fee disclosures to a particpant with the quarterly benefit statement, can it make use of these disclosure mechanisms (mechanisms provided in the answer to question 2)?
- Can a plan distribute the new investment information, incuding the comparative chart of designated investmenet alternatives, along with a benefit statement?
- Can the plan, without further notice, use IRS disclosure methods or 24/7 web access to provide investment information or other particpant fee disclosures which are not provided as part of the benefit statement?
- Is there an alternative to using the benefit statement or the cumbersome DOL electronic disclosure rules for e-delivery for investment information and other disclosures under the partcipant fee disclosure rules?
- What must the notice requesting the email address contain?
- When must the notice be provided?
- What additional requirements must these disclosures satisfy?
- What if the plan already has the participant's email address?
- May a plan administrator use the quarterly benefit statement to make the required disclosures of the participant fee disclosure regulations?
- How would a plan include the annual disclosures in the quarterly statement?
- Must a plan use the quarterly benefit statement to make the disclosures regarding the plan related information and the plan administrative and individual expenses?
- May a plan administrator use e-delivery to provide the quarterly benefit statement?
- What e-delivery methods may the plan administrator use to deliver the investment disclosures?
- What requirements must a plan comply with to take advantage of the alternative e-delivery methods of DOL Technical Release 2011-03?
- May the plan use e-delivery to transmit the notice requesting the email address?
- If the plan already has the participant's email address, may it use the email address under the alternative e-delivery method?
- May the plan use the alternative e-delivery method to disclose the plan related information and the administrative and individual expenses?
Baden Retirement Plan Services is developing fee disclosure information that it will share with its plan sponsor clients and financial professional contacts as it becomes available. Please
contact us with questions about the fee disclosure regulations.