Preliminary Informational Notice: 408(b)(2) and 404a-5 – Fee Disclosure
05/24/2012Service Provider Fee Disclosures
In general, ERISA §408(b)(2) requires each “covered service provider” to provide the responsible plan fiduciary (which usually includes the plan sponsor and trustees) with a description of the services provided and the associated direct and indirect compensation expected to be received for those services. The plan fiduciaries are expected to review these disclosures in order to determine whether or not their arrangement with these covered service providers is reasonable.
A “covered service provider” is any individual or entity expecting to receive compensation in excess of $1,000 over the life of the retirement plan (excluding payments made directly by the plan sponsor). Examples of covered service providers are the plan’s Third Party Administrator (Uniglobal), Recordkeeper, and Financial Advisor(s).
Specific plan-related and investment-related information must be disclosed to all “eligible employees” and beneficiaries who have the authority to direct investments in the account. These must be disclosed by the plan sponsors of participant-directed individual account plans. Eligible employees are all employees, regardless of having an account balance, that have met the eligibility requirements of the plan and are therefore considered a participant of the plan. Timing Requirements
The 408(b)(2) regulation is effective July 1, 2012, and the 404a-5 regulation is effective September 1, 2012. We at Uniglobal are working with your plan’s recordkeeper to provide the required notices before these effective dates. You can expect to receive further communications and instructions regarding these disclosures within the next few weeks. If you have any questions in the meantime, please feel free to contact your Plan Administrator at your convenience.This communication is for informational purposes only and not a disclosure notice from Uniglobal on services performed. Disclosures from Uniglobal will be in compliance with all regulations and delivered to all parties requiring disclosures. Uniglobal is neither a Fiduciary nor admitting any Fiduciary Role.