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Found 2 results

  1. Small DB plan Trustee pays for investment courses from Trust assets (about $1,500 from $750,000 of assets). Could this be construed as a plan expense? I think probably not, however, in the context of a DB plan for which the Trustee is main participant and ultimately having to meet minimum funding it may not make a difference. The ultimate question is whether this type of expense is proper to begin with or legitimately a settlor or personal (to the Trustee) expense. In the context of a DC plan it could make a difference.
  2. The vast majority of DOL guidance about when it may be appropriate to pass through eligible administrative expenses to the participant directly affected by the administrative action is limited to defined contribution plans. Question has come up whether you could do the same under a cash balance plan (assuming the expense is reasonable, it's reasonable to assess it to the particular person involved, etc.), which is, of course, a defined benefit plan but does have individual accounts. The only thing I can find on whether you could pass through expenses in a DB Plan is an informal DOL staff comment saying yes, specifically for the expense of QDRO administration, but would need DOL and IRS guidance on the issue. Has anyone seen any other guidance or comments on the issue?
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