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Monitoring Service Provider Compensation Is Continued Focus of Audits and Litigation (PDF)
Buck
Mar. 24, 2013
"[T]he fiduciary should re-evaluate the total compensation paid for plan services in light of [any] new information. If the additional income is significant, it may cause the current fee structure to no longer be 'reasonable'. At that point, further action on the part of the fiduciary may be necessary to reduce other fees to bring the total compensation in line. Depending on the length of time involved and the amount of the undisclosed compensation, it may be necessary to restore earnings back to the participants."
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