Following Lou S, what is the fee? Is it a fee applicable to every distribution? Or is it specifically a fee related to QDROs, as sort of suggested by your report on what the SPD says. If the fee "may" be charged ... , then who decides whether or not it is charged or charged to the participant's account? Looks like the plan administrator will have to interpret the ______ language of the SPD and answer all the other related questions.
I agree with John, that's pathetic. I saw an auto provision from a major (top 5) bundled provider's prototype the other day & it was a 6% initial enrollment, auto-escalating to 16%. The big boys are not following the logic that 6% is "too much", they're not stopping at the arbitrary 10% & my faith in humanity is still somewhat intact.
I agree with Tom. I have seen it show up as a contribution. But on an audit, I would have no problem explaining why I did not count earnings in the 415 limit.