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A Warning to 401(k) Plan Sponsors Who Are Relying on TPAs
McCarter & English Link to more items from this source
[Guidance Overview]
Apr. 13, 2015

"As the IRS has made clear, plan sponsors may not abdicate total responsibility to their TPAs to accurately track the administration and retain documentation of participant hardship distributions and loans. Therefore, plan sponsors should review plan records frequently, and ensure that they have regular access to, and can frequently audit, TPA records to remedy deficiencies as they occur. TPA service agreements should be drafted accordingly."

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