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Now that both the DOL and the IRS have sanctioned allocating certain plan administration expenses (such as QDRO preparation) to individual participant accounts, I would like to update some 403(b) plan documents accordingly.

From a practical perspective, however, how would this work if the plan assets are held in multiple individual TDAs, rather than in a group annuity environment? What if some TDAs permit allocation of expenses, but others don't? I am presuming the new plan language would defer to conflicting language in individual TDAs, but am open to all comments and suggestions.

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