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Posted

Quick question - want to see if I'm off base. Say you have a change to the fee information that can be charged directly to participant - adding or increasing loan fees, distribution fees, etc. So you generally have a minimum 30 day notice period before the change can be implemented. Fine. Question: is the SMM an acceptable method of notification? It seems to me that it is - 2550.404a-5(e)(1) allows incorporation into other documents under ERISA 102. Any other thoughts?

Posted

I'm with you. It should probably be part of the Annual Notice thereafter (or some document that coordinates with the Annual Notice).

Ed Snyder

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