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Posted

Thank you for this news.

And how much should a TPA bill its client for explaining the Inspector General's request letter?

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

I have not seen a letter, but if you're just talking about the "normal plans" I would not worry too much. I worry about the plan's with real estate because as far as I know it is very difficult to get a fidelity bond covering real estate (at least that's what I think I have heard). That's been our experience anyway.

But I think the biggest gotcha here is going to be the non-custodian record-keepers. I think a lot of TPA's (not those who frequent these boards of course!) miss that the SAR must disclose the custodian because the recordkeeper is not a "regulated financial institution." (i.e., Schwab is custodian but someone other entity is recordkeeper). That's assuming whoever is doing the review appreciates that finer distinction :).

Austin Powers, CPA, QPA, ERPA

Posted

Apparently he can make this problem go away for just "1 million dollars"

And of course, that's not really a lot of money these days...

Austin Powers, CPA, QPA, ERPA

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