Peter Gulia Posted 21 hours ago Posted 21 hours ago A fiduciary assembling an ERISA rule 404a-5 disclosure to participants and other investment-directing persons plans to use a “Sample Glossary Of Investment-Related Terms For Disclosures To Retirement Plan Participants” collected by The SPARK Institute, Inc. and other trade associations and related charities. The document the fiduciary has is labeled “Version 1.01 April 26, 2012”. A visit to https://www.sparkinstitute.org/resources/best-practices-industry-standards/ shows that 2012 version. But is that first version still the current version? If not, what is the current version? BenefitsLink neighbors, thank you for your gracious help. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
blguest Posted 15 hours ago Posted 15 hours ago I'd maybe try inquiring of Spark or ICI. I think you can email them at glossary@ici.org. Peter Gulia 1
Artie M Posted 13 hours ago Posted 13 hours ago Since it is on the SPARK website and the Spark website is updated, it seems like that would be the latest version. Note that Version 1.01 is actually the second version. The first version was originally issued in December 2011. Don't know the cite for this but I have this in my Spark definitions "file". The website does not state that this document is "maintained" but there are other resources provided on the website that are fairly current. SPARK could circulate a member-only update that is not publicly available but I've not heard of them doing so. From a practical ERISA perspective, if a client asked me whether using the SPARK glossary creates a problem because it is "old," I would generally say no (or at least it shouldn't). The DOL regulations require access to a glossary of investment-related terms. The key is whether the provided glossary (whether SPARK or not, or version 1.01 or not) adequately covers the investment terms that actually appear in the plan's disclosures and designated investment alternatives. The SPARK document itself expressly contemplates that plan sponsors may customize and supplement it. Peter Gulia 1 Just my thoughts so DO NOT take my ramblings as advice.
Peter Gulia Posted 1 hour ago Author Posted 1 hour ago A fiduciary might consider whether to delete or display terms not used in any of the plan's communications and also not used in any of any designated investment alternative's communications. I can imagine reasoning in either direction. Peter Gulia PC Fiduciary Guidance Counsel Philadelphia, Pennsylvania 215-732-1552 Peter@FiduciaryGuidanceCounsel.com
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