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Are ERISA Budgets Plan Assets? DOL Sheds Some Light
Thompson Hine Link to more items from this source
[Guidance Overview]
July 31, 2013

"[P]lan fiduciaries should: [1] Periodically review and evaluate the plan's arrangement with its recordkeeper. If the plan's compensation structure is asset-based -- including revenue sharing arrangements -- the plan fiduciary should monitor whether plan asset growth may warrant renegotiation of the parties' fee arrangement. [2] To the extent some or all of the recordkeeper's compensation is paid through a revenue sharing arrangement, evaluate whether the plan has or should seek an ERISA budget arrangement to recapture some or all of these payments for the benefit of the plan."

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