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We don't really do anything with ESOP's, but I was just curious: if/when this applies to an ESOP, does the TPA have any obligation, or is this just a corporate/legal reporting issue that the TPA does not need to worry about?

Posted

If a retirement plan’s circumstances include the trust’s investment in an employer security or a significant stake in a security beyond pooled investment fund shares, some TPAs drop a courtesy hint or reminder.

Some might do this quietly with the plan fiduciary’s lawyer, if the TPA has a working relationship with that lawyer. Otherwise, a TPA might suggest to the plan’s fiduciary that it ask its lawyer.

While many TPAs gives tons of legal advice (and on some topics know much more than many lawyers), the Corporate Transparency Act might be better suited for a handoff.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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