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service provider disclosure

Guest cbclark

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Guest cbclark

This may be in the wrong forum, so my apologies in advance. We are gearing up for the fee disclosure requirements under the new 408(b)(2) requirements, and a question has popped up about defined benefit plans. The final interim regulations specifically apply to DB plans, but what about the situation where the service provider/actuary sends the invoice to the plan sponsor who in turn sends it to the trustee for payment from the plan. The service provider is receiving compensation from the plan so the 408(b)(2) rules kick in. Is the invoice adequate disclosure for the fiduciary? Would some other disclosure need to be made? Seems logical if the fiduciary approves the invoice then the fiduciary had received the requisite disclosure...but as we all know, logic and ERISA are not always mentioned in the same breath! Thanks for your thoughts.

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