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You're not talking about forcing participants to self-direct; you already have that, but presumably there is a default under the existing platform for those who don't make an election. So, you, the idiot sponsor, or someone else, needs to figure out what to do with accounts for participants who do not make an election. You can not, literally, force someone to direct their account. What is proposed is not a good idea, to understate the case. Sponsors think that if they let everyone do whatever they want, they avoid liability. Not so.

The thing that jumps out at me is that the participant retaining your services has a divorce consultant and you, but no counsel while the alternate payee has counsel. That needs to be addressed.

If there was a QDIA in place I would think you can.....but my experience tells me that forced self direction is a train wreck waiting to happen.

Good call, ESOP Guy. That sounds right. And isn't this aimed at service providers who get more than $5k (I haven't looked it up), not about the sponsor's employees?

Are they trying to apply incorrectly some of the Sch C fee disclosure rules? I quote from the Sch C instructions: You must enter the information required for each person who rendered services to or had transactions with the plan and who received $5,000 or more in total direct or indirect compensation in connection with services rendered to the plan or the person’s position with the plan during the plan year. I would call it a bad reading but I could see how someone might read this such they needed that information. To me the "person" paid is the TPA firm but they could be reading the word person more literal.