404a-5 requirements

[Will]

If a quarterly participant statement reflects all fees and expenses deducted from a plan does that meet the annual 404a participant disclosure requirements? 

[Pam Shoup]

If all it shows is the fees an expenses, then no it does not. 

When you open the regs, there is a model notice provided.  Among other things is a a requirement that the plan states if it intends to be an ERISA 404(c) plan, contact information, how often the participants can give investment direction, information on any sources or funds that have restricted trades, the types of expenses that could potententially be charged to their account, a comparative chart listing fees and expenses versus a benchmark, as well as performance information versus a benchmark.  Website addresses are included to find up to date information, and other information such as if the plan contains fund models (fund of funds) or a self-directed brokerage account as well as a statement regarding the cumulative effect of fees and a glossary, or a link to a glossary of terms.  That's from memory and I am sure that I missed a few points.