PPA disclosure statement in a pooled plan

[AlbanyConsultant]

Is anyone still doing anything on this?

I remember back when PPA first came out (you know, when we thought we'd actually get real guidance within 12 months), many TPAs took the position that as a good faith statement, we'd provide the asset listing of a pooled account (or a copy of the account statement), and my firm did, too. Now it's five years later, and we're still attaching asset lists, and clients are starting to question it (because they have short memories).

A quick survey of TPAs today revealed that almost none were still doing this. In fact, one mentioned that it was brought up at a recent conference, and Steve Forbes thought it was unnecessary. Thoughts?

[Jim Chad]

I am still doing it. FWIW

[Bird]

We're doing it. Still waiting for that required guidance from the DOL...

[ESOP Guy]

Still doing it. It is the law even if not well defined.