Well, technically, we didn’t write this idea on the beer napkin, but the thought occurred to us to do so as David John and I were sitting in a restaurant at Union Station quaffing one or two. The beer napkin was too wet to write on, but here’s the idea as best I remember it.
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DOL’s Fiduciary Proxy Voting Rules Makes Upcoming Proxy Season “Dicey” for Plan Fiduciaries
By Robert Toth on
Posted in Uncategorized
Its going to be a demanding year for fiduciaries of retirement plans, particularly of those in the small and mid-market which are not particularly accustomed to paying close attention to them. I have blogged earlier on the increased fiduciary demands related to the new data provided to fiduciaries under the 2008 Form 5500 Schedule C…
2009 Form 5500 Schedules A and C Will Create New Fiduciary Burdens For Plan Sponsors
By Robert Toth on
Posted in Uncategorized
Retirement plan vendors throughout the industry are engaging in efforts to prepare for the new disclosure requirements for the 2009 Form 5500 schedules, particularly the disclosures related to direct and indirect compensation under Schedule C and the substantial requirements for Schedule A.
I had the pleasure of a couple of informative conversations this week which…
403(b) Fiduciary Challenges Demand Applying ERISA in Unique Way
By Robert Toth on
Posted in 403(b), Uncategorized
So what are we finding as we get down to this nitty gritty of things? Most striking is the unique ways in which ERISA’s fiduciary rules will need to be used in their application to ERISA 403(b) plans. It is not that the rules were never there in the past, it is just that the new rules have forced the industry and employers to more closely define their relationships and the duties for which vendors and employers will each be responsible. This process of defining roles have caused us all to look more closely at how the rules apply, in ways we have never done in the past….Let me give you an example…What are the ERISA implications of a fund substitution under individual annuities for the 403(b) plan fiduciary?
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