Paying TPA Fees from Plan Assets

What sort of notice may be required to pay our TPA fees from Plan Assets. We still have not been paid for 2019 services as the client's business has been heavily affected by Covid so a thought about paying our services from Plan Assets came up. Our document allows for this and this seems like an allowable fee to charge to participant accounts but was wondering if I was missing anything about having to let participants know about this. We would likely do the same for 2020 services as well.

Is the plan participant directed? Are you looking to take fees from forfeiture or from participant accounts? Did the participant fee disclosure state that TPA fees might be paid from their accounts?

Participant Directed. Looking to take fees from participant accounts. There are no forfeiture money in the Plan. The Fee disclosure doesn't specifically mention TPA fees. It is generated from a recordkeeper. We do not charge any participant fees for distributions etc.

Participants will need to be provided at least 30 days in advance with an updated fee disclosure that explains the fees which may be charged against their account.