Tacit in the language of the DOL’s proposed prudence safe harbor requirement that a fiduciary “read and critically review” the investment documents supporting a broad range of often commonplace DC investments is, I would think, the implication that the documents provided to the fiduciary should, indeed, be “readable.”
There are really two different types of
The DOL’s proposed prudence safe harbor regulations have pretty much made it “table stakes” for some responsible person somewhere to read and understand any annuity contracts on behalf of the plan which are provided as part of any DC lifetime income program. This means, of course, you have to first know where those annuities are
This topic has never been one that has much concerned either analysts or operators of programs which involve the purchase by a DC plan of an annuity contract. This one has always been in the purview of the engineer-those insurance legal and compliance folks who have well established procedures to deal with each state’s insurance
One of the key fiduciary roles in the assessment of any DC lifetime income program process necessarily involves whether, and how, the plan or the vendor accommodates any required spousal consent rules related to the payout of annuities.
The vast majority of the defined contribution plans comply with ERISA and the Code’s spousal consent rules
Often overlooked in a fiduciary analysis of any DC Lifetime Income Program are the impacts arising from the method in which any accumulated lifetime income guarantee is being distributed from any particular program. There are substantial differences between any of the available methods, and the impact of each of them on any participant. They really
We have all been well attuned over the decades since mutual funds became available to be daily traded under DC plans to a very particular view of an investment funds’ cost. ERISA’s participant investment disclosure rules have successfully established what I best described as a certain “language,” which permits any participant or fiduciary to assess
“No Duh!”was my favorite response by a colleague to the DOL’s alt asset proposed regulation, which is replete with references to the need of the fiduciary adviser to “read and critically review” the core documents of any of a plan’s investments. That proposed reg does grant plan sponsors some grace, only requiring that they (who
Business Wire published a news release today announcing the new strategic relationship between Securian Financial and Custodia Financial regarding Custodia’s Retirement Loan Protection (RLP) program—”a first-of-its-kind, in-plan feature that helps safeguard employees’ retirement savings by automatically protecting 401(k) loans from default when job loss, disability or death occurs.” It is a program a number of
403(b) plans and lifetime income programs suffer a similar malady: both sorts of arrangements operate in a sort of “exception” environment, where they rely upon atypical application of the standardized qualified plan rules in order to effectively work. This means that these programs are not typically amenable to broad and sweeping policy statements of the