Fee Disclosure during a Transition to a New Provider

[hightower.texas]

I’m interested in learning more about how Plans account for fee disclosure change notices during their transition to a new provider/recordkeeper. As transitions can take a few months to work through Plan details, determine new fees (plan level and individual fees), and finalize how the investments will transfer; it seems having the change notice to participants 30 days prior to their first opportunity to choose investments could be tough.

Does anyone have experience with these notices and how you've handled it in the past, specifically when the assets are “mapping” to new investments and the blackout begins about a week prior to the effective date. In this scenario participants wouldn’t have access to their accounts until after the blackout ended.