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How do participants get managed-account documents?


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I hope BenefitsLink neighbors will help me by responding to this survey about methods and customs in delivering documents for a managed-account service.

Assume an individual-account retirement plan that provides participant-directed investment. Assume the plan’s top fiduciary approves a registered investment adviser’s offer of its managed-account service. The service is provided only to a participant (or other investment-directing individual) who agrees to the extra service, and agrees that the investment adviser’s fee is charged against her plan account.

Does the adviser deliver its investment-advisory agreement:

1)        as a paper document?

2)        as a pdf attached to an email?

3)        by showing a hyperlink that points to a webpage on which the agreement is hosted?

4)        by some other means, and if so what?

Does the participant/advisee sign the agreement:

1)        with ink on paper?

2)        using an electronic-signature service?

3)        by clicking an “I approve” button in the plan’s or the adviser’s website?

4)        by some other means, and if so what?

When the adviser later must deliver a required disclosure, is it:

1)        paper sent by US mail?

2)        a pdf attached to an email sent to each participant/advisee?

3)        a notice-and-access email with a pointer to the website on which the document is hosted?

4)        notice in a quarterly statement?

5)        by some other means, and if so what?

Thank you for your good help and practical observations.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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