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Yes, I would. It would be impermissible to pay settlor fees from plan assets, so if the DOL used those payments as indications of an ERISA plan, it would make it impossible to have a non-ERISA plan. I was interpreting "related 403(b) fees" as meaning fees associated with the management of assets under the contract itself.

Yea, well, one year is eons for a client who sees this as a cloud hanging over their heads.

False. While you can do the backdoor IRA, if you already have pre-tax money in one or more IRAs a portion of the amount converted will be taxable. Rough Example: You have $45,000 in a pre-tax IRAs from the days when you were able to make tax-deductible IRA contributions. Now, on Tuesday, you make a non-deductible contribution to a separate IRA of $5,000, then on Wednesday you convert that IRA to a Roth. You can do that, but only $500 will be tax-free, and $4,500 will be taxable.