Leaderboard

It is if you're not fully reconciling assets (we are, generally). I'm not arguing with you, it's not complicated if your systems are set up right. Maybe I don't get out much but I get the sense that there is widespread noncompliance.

We have a lot of pooled plans and we provide a list of Assets & Liabilities with the SAR & benefit statements. From what I have seen, most practitioners provide a similar A&L. Its either a list of assets and liabilities with amounts at the end of the year, or a list with amounts at the beginning and end of the year. Not that complicated.

They are required to furnish the Summary Annual Report - which for trustee directed pooled plans is required to contain some investment information.

Yes. Often when you hear bizarre statements like this, it is the client re-stating what they think they heard from the TPA, not what the TPA actually said. This is not always the fault of the client. It is incumbent on us to constantly strive to communicate clearly with clients. It is difficult, as this is a very technical area where logic doesn't necessarily apply, and our industry jargon does not help. A favorite of mine, how many times has a prospect or advisor told you their HCEs keep getting ADP refunds because the plan is "top heavy"?

Wow! Good thing they now have a new TPA. For poops and giggles, I'd have the client go back to the prior TPA and ask them what the penalty is (and for maybe a cite). Have them say the new TPA doesn't know what they are doing and they want some clarification.