I have noticed a curious perception with regard to all of this activity related to 12b-1 arrangements, which gives me some pause. There seems to be a growing sense of entitlement, that somehow plans are entitled to revenue sharing, that there is some sort of innate (and perhaps legal) entitlement plans have to the 12b-1 and service fee payments generated under these programs. It seems that often this is where the conversations begin, and is even seems to be creeping into some of the DOL’s own approach to these things.
Continue Reading Keeping 12b-1 Basics in View When Reviewing Plan Revenue Sharing
October 2012
The EPCRS and Audit Test of the 403(b) Regulations
By Robert Toth on
Now with EPCRS, we are told, being on the verge of release, and with 403(b) audits beginning to enter a new, what I would call “normalized” stage, the 2007 regs will truly be put to the test.Where this will have its impact is when you have to drill down and attempt to apply the regs in detail to any particular fact circumstance….
Continue Reading The EPCRS and Audit Test of the 403(b) Regulations
MEP Reflections Following the GAO Report
By Robert Toth on
Posted in Multiple Employer Plans
The GAO issued its long awaited study on Multiple Employer Plans. It is nicely written, and for those who with an interest in such matters, it’s a good read.
It pretty well summarizes the current state of affairs related to MEPs. The report, along with our own recent review of MEPs, really demonstrates a
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