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1st Golbal Valuation Program


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1st Golbal has set up a program that requires participants to make investment changes and transfers online (no 800 access). I was wondering what anyones thoughts on this approach are?

Not everyone has internet access. COuld this create a DOL issue. At a minimum it will shift additional responsiblity back to the employer to make sure all participants have access to their account information.

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Guest Carol Ringwald

I am currently working with a couple of firms that will be offering only an internet solution and no 800 number. However, I have suggested to them that they must also make available the ability for a participant to complete a paper transfer form that they send to their employer for authorization. This way, the TPA firm can be assured that the transfer is really from a valid participant in the plan. The TPA has also decided to charge a fee for this service since the participant is not using the Internet access.

The main reason that the TPA is not making a voice system available is because they believe this is "old" technology and it is fairly expensive to implement (to the tune of $30,000 or so). However, I suggested to them that they need to have another means of letting the participant make a transfer selection other than the Internet since Internet access is not as readily available as the telephone.

I'm not sure if you would have a DOL problem or not. I think you would have a problem if the plan document indicates that transfers are available to a participant and then not have a reasonable means by which the participant can make the transfer request. The question is whether or not the Internet is "reasonable means". Perhaps you might contact the DOL directly about this in light of their views on paperless administration of pension plans.

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