annual fees

[Felicia]

Does anyone charge annual fees for non-ERISA 403(b) plans? If so, who is charged: the employee's account? the employee directly? the employer? any combination?

[GBurns]

Doesn't your 403(b) consist of individually owned investment accounts or annuity policies? If so, shouldn't individuals pay for that which individuals own and control?

[Lori Friedman]

Since the issuance of Rev. Rul. 2004-10, it's becoming increasingly common for 401(k) plans to charge "reasonable", nondiscriminatory administration fees to participants.

A non-ERISA 403(b) plan, however, isn't administered by the employer. The organization is limited to the role of conduit: withholding contributions from employees' paychecks and forwarding the funds to an investment or insurance company. I'm curious what costs are incurred by your organization: the time spent by your accounting staff to generate the payment checks, or perhaps the postage costs to forward the payments? I'm guessing that these costs would be very immaterial to your organization.

[GBurns]

Who is charging and for what?

[Appleby]

Our charge- annual custodian fee fora 403(b(7) account = $50.

Other adhoc/per transaction fee may apply for distributions VIA fed fund wire & processing loan requests...

[Felicia]

Appleby: do you charge the account? send a bill to the participant? send a bill to the participant with the option to take from the account if participant does not pay the fee?

[Appleby]

We send a bill to the participant, giving him/her the option to pay the fee out of pocket. If the fee is not paid by certain deadline, the fee is debited from(charged to) the account.

[GBurns]

What you have described is what I have always seen as standard practice, whether for 403(b), 401(k) or even IRAs.

The account holder (participant) gets a bill with a deadline to remit payment out-of-pocket, which if not met leads to a deduction from the account.