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Posted

In 1992, the DOL published Final Regulations Regarding Participant Directed Individual Account Plans to advise fiduciaries on appropriate action to seek the protection of 404©. ( 57 Federal Register pg 46906, published on 10/13/1992.) This publication stated that particpants and beneficiaries when submitting investment instructions had the "opportunity to obtain written confirmation of such instructions."

Now if the participant makes investment elections through the internet, he or she gets a confirmation number and/or can print out the screen. In this instance, I think we're in compliance. If we wanted, we could also print a Relius Confirmation report and mail it.

But what if they send a written request to our office and we enter the instructions through the Census Screen, Allocation % tab? I've been told the Relius Confirmation report does not run when trades are entered in this fashion. (My partner runs the Relius system so I might not be using the correct terminology.)

Can someone volunteer how they handle this issue?

Thanks.

Guest DottleC2
Posted

I would presume from your post that the participant has asked for confirmation within her written request. Otherwise, the next statement she gets will show what she requested. Also, I assume that the employer had some oversight and was watching the paper trail - in other words, you weren't subject to a deluge of written requests coming in on behalf of the participants that the employer wasn't aware of.

Have disclaimed to the hilt, I would enter the percentages in a file in the client's folder that is imported on a regular basis into Relius.

A copy goes in the elections file and end of transaction. If I see too many participant requests, I ask the employer or HR department to intercept.

Regards,

Bill

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