cdavis25 Posted February 28, 2013 Posted February 28, 2013 A company has a DB Plan that they are going to terminate. They want to move any excess assets to their 401(k) Plan. I know they can use this ratably over 7 years to pay for nonelective contribution and reasonable admin fees. Will the platform recordkeeping fees (i.e. ING recordkeeping charge say 20 basis points) be considered acceptable admin fees?
John Feldt ERPA CPC QPA Posted March 4, 2013 Posted March 4, 2013 It's a fiduciary question. For the services provided and the amount of assets involved, is 20 bps reasonable? It depends on all the facts and circumstances.
david rigby Posted March 4, 2013 Posted March 4, 2013 IMHO, regular DC admin fees that are reasonable in and of themselves, will be considered reasonable under IRC 4980(d)©. However, it's been a few years since I looked at this section. Read carefully. (There was an IRS Notice/Announcement/Rev Ruling on this section a few years ago.) But, it's just my opinion. I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.
rcline46 Posted March 4, 2013 Posted March 4, 2013 Exactly how would the 20 basis points for the entire fund be directed to just the holding account? I don't think ING can separate it and so charge it.
cdavis25 Posted March 6, 2013 Author Posted March 6, 2013 I just used ING as an example. I did not want to disclosure any specifics. I am not sure how the vendor would do it. I was just wondering if others felt it would be reasonable.
Recommended Posts
Create an account or sign in to comment
You need to be a member in order to leave a comment
Create an account
Sign up for a new account in our community. It's easy!
Register a new accountSign in
Already have an account? Sign in here.
Sign In Now