ERISA_Guy

The client's goal is likely to allow a way for participants to have their hypo account balance online so they can "see" it, so it feels more real, so that the "retirement readiness" algorithms can include that balance in their projections. This can be done by adding the plan as "trustee directed" at the same recordkeeper who does the clients 401k. it would not be updated more frequently than now: annual determination, annual crediting. It would just be visible. The fiduciary aspect would be "can the CB investment advisor use the fund lineup to create a portfolio?" if you can get buy in there, this is a good way to accomplish your goal.

1. the plan's liability is 1099 reporting (and withholding) errors -- the plan is liable for the tax if they get it wrong. The form has to pass the smell test, the plan must confirm the form info. 2. a "we don't check, we just withhold to be safe" policy doesn't work.

"Required" by what? Your service agreement may say something about what you will do for the client, so that'll be required. For IRS purposes, i don't think there is a requirement to have a report on testing. The requirement is that you pass all tests. Passing is "required", reports are not "required". Of course not passing is bad and correcting is good and way easier if corrections are made within certain windows that you'll only know if you do the test. So the TPA industry is built upon performing and providing reports as part of the "policies and procedures" the Sponsor has in place. I have seen each unrelated employer treated as a single employer for valuation/reporting purposes and complete report/valuation packages sent to the whom the TPA was asked to send it. That was sometimes the Plan Sponsor (they got all participating employer reports and did what the wished with them) and sometimes the adopting employer level. Clear communication of expectations reduced to clear service agreements (TPA to PEO, PEO to Participating employers) lead to what's required, which to my mind should align with what's useful.

I don't think there is a writing requirement, the policies just need to be "real". In other words, the plan has to have and follow policies designed to be compliant, but these policies don't have to be written in detail.