Charging fees to participants for changing tpa

[TPApril]

Plan Sponsor normally charges annual administrative fees to all plan participants.

Client has changed tpa.  Can same plan sponsor charge the following fees to participants:

• Plan Document restatement by new tpa when the restatement is not a required restatement but just from changing tpa
• 'Transfer fee' by old tpa for providing participant data to new tpa

[Mike Preston]

Technically, yes, yes.  But should it?

[Larry Starr]

11 hours ago, TPApril said:

Plan Sponsor normally charges annual administrative fees to all plan participants.

Client has changed tpa.  Can same plan sponsor charge the following fees to participants:

• Plan Document restatement by new tpa when the restatement is not a required restatement but just from changing tpa
• 'Transfer fee' by old tpa for providing participant data to new tpa

Agree with Mike; I'm guessing your plan document (existing one) allows for those fees to be paid by the plan. Did you check the language?