408(b)(2) notice questions

We have a 401k client whose plan funds are in brokerage accounts (each participant has their own - so no pooled);  We do admin. work only for this plan and bill the Employer - not the plan.  Are we responsible for providing this notice or does the brokerage account provider need to disclose fees, etc on such a notice?  Thanks!

Each covered service provider is responsible for disclosing to the plan sponsor of any fees it receives from any source other than from the plan sponsor.

If the broker account provider is receiving payments from the participants' accounts or from investments held in the participants' accounts, then the broker account provider is responsible for disclosing all such fees to the plan sponsor.

If all of your fees are paid by the plan sponsor, then you have nothing to disclose.

https://www.dol.gov/sites/dolgov/files/EBSA/about-ebsa/our-activities/resource-center/fact-sheets/final-regulation-service-provider-disclosures-under-408b2.pdf