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Consolidate 457(b) Vendors


kmhaab

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Plan sponsor wants to reduce number of active investment vendors under the 457(b) plan from 5 to 3.  They will close the 2 discontinued investment vehicles to new contributions,  but will allow participants to keep their current balances in those investment vehicles (for now). Going forward, new contributions may only be made to the 3 remaining vendors. 

I can't find anything under federal, state or relevant local law that governs these changes or addresses any participant notice or timing requirements).  Other than any potential collective bargaining agreements, am I missing anything?

 Is there a required notice period?

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Well, if it is an ERISA top-hat plan ERISA does not regulate this and state law cannot apply.  Is there anything in the controlling plan document that might say something about this?

If it is a church plan or a governmental plan, if you can't find anything in state law (assuming your search was comprehensive), then I guess you're done, assuming the plan document doesn't say anything about this.

With all that said I think you need to give some reasonable notice and devise and articulate a strategy for investing the money that had been directed to one or both of those two investments if the participant does not provide new investment instructions.  

  

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