404(a)-5 Disclosures

[msmith]

The recent DOL FAB (#2013-02) announced their temporary no enforcement action if a Plan Sponsor does not provide the Investment Comparative Chart by August 25, 2013 (assuming a Calendar Year plan).

Some of the Recordkept 404(a)-5 disclosures contain other information in addition to the Investment Comparative Chart.

Has the disclosure of this information been extended as well?

[Below Ground]

How would the Investment Comparative Chart be designed for a Plan that only uses Self Directed Brokerage Accounts?

[Bird]

How would the Investment Comparative Chart be designed for a Plan that only uses Self Directed Brokerage Accounts?

It's not. I don't remember all of the details, but a brief synopsis of what I do remember is:

• the DOL originally said you had to pick something like 4 options and prepare a chart for them.
• there was a hue and cry over what a PITA that would be.
• they said "never mind (but we really, really don't like these accounts."

[Below Ground]

Thanks Bird. You are always a great resource!