Business of Benefits

Business of Benefits

Category Archives: Fiduciary Issues

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FAB 2012-2/ Q15’s Impact on 403(b)

Posted in 403(b), Fiduciary Issues
One of the more difficult questions that has arisen under the 404a-5 participant disclosure rules is related to those pesky "old" 403(b) contracts. In the multiple vendor ERISA world, where a number of vendors have been in and out of the plan over decades, the question becomes whether-and to what extent-the 404a-5 disclosures have to… Continue Reading

Behind 408(b)2’s Looking Glass: Parties-In-Interest, Non-CSPs and Other Complex Tales

Posted in 408b2, Complex Prohibited Transactions, Fiduciary Issues
Now that the initial 408(b)(2) disclosures are out, the challenge becomes understanding them. Beyond just understanding whether or not the fees disclosed are reasonable (a challenge in itself), the disclosures do something arguably more important: they take us behind the looking glass, opening a window to a world with which most are not familiar, but… Continue Reading

Important 408(b)(2) Relief for 403(b) Plans

Posted in 403(b), 408b2, Complex Prohibited Transactions, Fiduciary Issues
The DOL continues with its sensitivity to the challenges created for 403(b) plan sponsors in the transition to an employer accountable world. In today’s release of the final 408(b)(2) regs, the DOL provided tremendously needed relief for 403(b)plans. The language from the preamble speaks for itself: The Department was persuaded by commenters on the interim final rule… Continue Reading

Minutiae’s Triumph: The Striking Impact of Transparency, the Prohibited Transaction Rules and the Exclusive Benefit Rule

Posted in 408b2, Complex Prohibited Transactions, Fiduciary Issues
Freedom and liberty are not merely themes sounded by politicians in political campaigns, or in rousing marches by military bands (though I am personally  particularly fond of them!), nor are they ideas which you will typically see being discussed in a piece about retirement issues. But they are themes woven into the fabric of our… Continue Reading

The Flushing Effect of the 403(b) Connection Between 408(b)(2), Participant Disclosures and Plan Audits

Posted in 408b2, Complex Prohibited Transactions, Fiduciary Issues
I would think that it is a basic law of physics that, whenever you attempt to apply a number of different and complicated principles to a single object, that the consequences on that object will be hard to predict, or even readily ascertained. So it is with a potential impact 408(b)(2) may have on many… Continue Reading

For Guaranteed Lifetime Income in DC Plans: (ITS) Time Has Come Today

Posted in Fiduciary Issues, Lifetime Income
But, first, another note of introduction…… It is with great pleasure to announce that my friend and fellow pink-shirted compatriot (many of our industry colleagues may fondly remember THAT story!) Sandy Koeppel has decided to join us as Of Counsel, and to have some fun following his illustrious career at Prudential.  Together with myself, Phil… Continue Reading
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