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Posted

Is there any guidance on if a trustee is required to give participants notice prior to charging TPA fees to participant accounts? I have a trustee who will be terminating their plan and wants to pass outstanding TPA fees onto remaining participants (less than 10) on a pro-rata basis. For example, one participant would be charged $900. The trustee doesn't want to give notice to the participants - he just wants to process the fees. It seems to be an ethical question at the very least.

Thanks

Posted

What does the plan's SPD say? If it references that participants may be charged fees you are probably OK. If not an updated SPD or SMM might be in order.

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