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Found 2 results

  1. We provided fee disclosure for a Plan transferring to a new service provider. The Plan offers Target Date funds - although to date no one has selected. We did not include all the Target Date funds in the initial fee disclosure. I know we need to provide disclosure but wonder if this is subject to the 30 day notice requirement? I am wondering if this would qualify as a "special situation" in the DOL guidance?
  2. General question about timing of change notice for 408b2 as it relates to new fund additions at a product level. If a company is going to add new DIAs to the potential fund lineup for a product, when do you think the 60 day clock (became aware of the change) would start for purposes of providing a change notice for 408b2? For example, if the new DIAs are going to be "available" for a plan sponsor on July 31, do you think the change notice would need to be effective by 6/1? The timing of these 408b2 notices and the information needed to satisfy 404a5 component of 408b2 makes timing of notices difficult and certainly subject to some interpretation.
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