408b2 - mutual fund investments in DB, CB plans

[CLE401kGuy]

For DB / CB plan 408b2 disclosures - do the mutual funds need to be listed in the 408b2 disclosure with net expense ratio, 12b-1, etc.? - we have been including the current funds in which the plan is invested in our 408b2's, but since these are not directed plans and thus there are no designated investment alternatives, i don't think we need to list the funds out... thanks!

[ETA Consulting LLC]

I am not sure if you're confusing the 408(b)(2) with 404(a)(5). The participant disclosure is under 404(a)(5) and would not apply since there is no participant direction. 408(b)(2) is for th employer to ascertain the costs of maintaining the plan; where the costs of the investments is very relevant.

Good Luck!

[CLE401kGuy]

i'm looking at 408b2 on CB, DB plans - so no 404a5 is required - we would have for instance investment advisory fees, plan administration and distribution processing fees that may be paid out of the plan which would need to be disclosed - since we act as the financial advisor as well as the TPA we have a full disclosure of all fees and I'm wondering if I really need to list the mutual funds within the 408b2 disclosure - my thought is that I don't need to do that - and only list our administrative and advisory fees... Thanks! I appreciate the quick response

[ETA Consulting LLC]

I "think" that once you are a covered service provider, you must list 'all' fees; regardless of what they are attributed to. I'm shooting from the hip on this one as I haven't read those rules in over two years; but that's the impression I got when I read them.

Good Luck!