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Sharing the Wealth: DOL Clarifies Treatment of Revenue Sharing Under ERISA
Dechert LLP Link to more items from this source
[Guidance Overview]
July 15, 2013

"[I]n those cases in which all or a portion of the revenue sharing is agreed to be for the account of the investing plan, the provider may wish to review its arrangements (i) to confirm that, in accordance with a controlling agreement or at the direction of a plan fiduciary, (A) credits are applied to pay plan expenses or (B) amounts equal to the credits are deposited into a plan account, and (ii) to confirm that no segregated or otherwise separate fund is established in connection with any allocation of all or a portion of revenue sharing back to the investing plan."

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