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Posted

We have what I shall euphemistically refer to as a "difficult" client who doesn't like to provide any information that we ask for.

They recently sent us an e-mail with a section that had been cut and pasted from somewhere unknown, asking for information on costs of any Defined Benefit and Defined Contribution plans. Client referred to this as a "us census data request." Although we are trying to get additional details, as I said, client is difficult and may not provide.

I was just curious if anyone had ever seen any type of similar request, or could fathom a reason? I doubt it is a scam, although of course it could be, but I'm having trouble imagining what, if any, government agency would be asking for this and why. Don't think there is anything connected with the ACA that would request this...

Anyway, any thoughts appreciated.

Posted

I may be wrong, but it couldn't have anything to do with ACA. There is no interaction between ACA and defined benefit or defined contribution plans (or at least none that I know of).

Not to say that there is no information ever requested for census purposes with respect to defined benefit or defined contribution employer costs, but I had never heard of any such need.

Is your client so difficult that they would not give you any information with respect to something they asked you to do for them? Not that it is easy to get to that point, but a good term for such a client is "ex-client".

Always check with your actuary first!

Posted

Perhaps your client has fallen victim to a scam.

Or, a "helpful" brother-in-law.

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.

Posted

If it is a scam, it would not be a matter of anyone gaining inappropriate access to plan assets. If it were an attempt to gain confidential information under false circumstances, that could be a problem, but aren't such pieces of information as the the employer cost a matter of public record (i.e., Form 5500 filings can be accessed by anyone online).

It may be bogus, but what would anyone stand to gain if it were? That's the part I don't understand.

I go back to the idea of telling your client that you don't know what the request is for, and that if they want you to help them respond to it, you will need more information. If they are as uncooperative as you have indicated, that will be the end of it. It's hard enough, with such clients, to do the things you know are required. Let slide those things that you don't know why they are needed.

Always check with your actuary first!

Posted

Agree with the comments, but I"M curious now as to what it is all about. Hopefully they will be more forthcoming with the source of this "request" for information.

If I find out anything interesting, that isn't confidential, I'll post it.

Posted

Ok, client provided us with more information.

This is, in fact, a survey from the US Commerce Department, Census Bureau. If is sent to some employers (whether a random survey, or some other method I couldn't say) and it asks them a ton of questions about all of the costs/expenses to run their business. And one of the costs is employee fringe benefits, hence the question. I don't know how many employers ever receive this, but I expect most of them just complete it without ever contacting the TPA, which is probably why we've never heard of it.

Evidently, response is legally required, so it isn't a voluntary survey.

You learn something new every day...

Posted

I'll bite. Why is response "legally required"?

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.

Posted

There is actually "a law" that requires responses to Census inquiries - both the "every 10 year" variety, and various other interim surveys. Congress empowered the Commerce Department to compel responses as 1) the Constitution mandates the every 10 year census for representative apportionment, and the others for "data collection" for policy purposes.....

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