I've looked a a variety of loosely related threads but none get to the heart of my question so I'll ask it here. I have a plan sponsor that would like to pick up ALL fees for plan participants, including fund fees. The plan uses a combination of pooled funds (CITs & MFs). Shy of converting everything to SMAs or having the fund companies develop an entirely new class of funds that are stripped of all fees (both unlikely for different reasons), this seems like it would involve some form of sponsor reimbursement to the Plan. Key concerns identified so far that I'm looking for insights on:
Is there a viable path to get these fees reimbursed by the sponsor to get to the intended result without running afoul of various rules pertaining to employer contributions?
Is there a viable path to get these fees reimbursed by the fund company that doesn't involve the employer making a reimbursement and thus avoiding the challenges of them being considered an employer contribution?
Related to this 2nd approach, it seems that the the Revenue Sharing rebate analogy may be useful (the practice or recapturing and rebating 12b1's, SubTA, etc. without them being considered an employer contribution). Could that analogy be extended so that the entire Expense Ratio is rebated in the way revenue sharing is?
This is one of those topics where I fear that the employer has a reasonable & positive motivation but the legal and operational hurdles might be difficult or impossible to overcome.
