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Participant fee disclosures in SPD


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How do others handle disclosure of fees for distributions and such in the SPD? In great detail, not at all, or with an addendum?

FTW gives us an option to use an addendum but then we still have to go into detail. Can we just say "refer to the fee disclosure document?"

(Of course) I am referring to plans that are on a recordkeeping platform where distribution fees are typically deducted from a participant's account, per participant fees for ongoing services, etc., and they prepare a fee disclosure document. It's such a pain to keep track of the different fees with different recordkeepers, and then our fees might be different by plan, and god forbid anything should change and you have to do an SMM or new SPD. I know it's been discussed before; thanks for any refresher info.

Ed Snyder

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Nice question.  I'm interested in hearing others opinions.  I will confess, for us we stopped trying to include fees in SPD a few years ago when I noticed that every SPD that we saw in a takeover situation did not mention fees specifically.  We use FTW and go with the default language that describes the types of fees that might be charged an refers them to the Plan Administrator for more information.

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15 hours ago, Gilmore said:

it just makes sense to us not to compete with the 404a5 disclosure

Exactly. When you start putting the same thing in multiple places, but it's not actually the same, then you have a problem. Trying to do too much can be harmful.

Ed Snyder

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On 9/21/2022 at 8:38 PM, Gilmore said:

We use FTW and go with the default language that describes the types of fees that might be charged an refers them to the Plan Administrator for more information.

Just to put a wrapper on this...my problem was not understanding the FTW checklist. The question reads something like "Will the plan charge participants for plan expenses?" and I did not want to say "No."  But saying "No" actually gives language that says something like "The plan may charge participants for plan expenses - see the Administrator" (as you note above, thank you!). And that's just what we need.

Ed Snyder

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