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Posted

The fee disclosure that was provided to participants  didn't include all the TPA fees being deducted from participant accounts.  I can't find anything that addresses what the correction procedure is.   Can anyone offer direction? 

Posted

The fiduciary loses 404(c) protection. There's nothing to fix except to provide the correct disclosures as soon as possible. And hope the participants aren't feeling litigious.

Free advice is worth what you paid for it. Do not rely on the information provided in this post for any purpose, including (but not limited to): tax planning, compliance with ERISA or the IRC, investing or other forms of fortune-telling, bird identification, relationship advice, or spiritual guidance.

Corey B. Zeller, MSEA, CPC, QPA, QKA
Preferred Pension Planning Corp.
corey@pppc.co

Posted

The fee disclosure probably doesn't have the same deadline as stuff like safe harbor or automatic enrollment notices, as well.  So you can run with that and update the fee disclosure notice.

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