July Business Services
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Pollard & Associates
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Great Lakes Pension Associates, Inc.
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Retirement Planners and Administrators (RPA)
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Regional Sales Director (West) July Business Services
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Defined Contribution Account Manager Nova 401(k) Associates
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Retirement Solutions Specialists
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Fringe Benefit Group
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TPA Retirement Plan Consultant EPIC RPS (TPA/DPS)
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July Business Services
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Greenline Wealth Management
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Senior Specialist 401k Recordkeeping T Bank N.A.
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New York City District Council of Carpenters Benefit Funds
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Defined Contributions Compliance Consultant Loren D. Stark Company (LDSCO)
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DOL Releases Proposed 408(b)(2) Fee Disclosure 'Guide' Regs (PDF)
Steptoe & Johnson LLP [Guidance Overview] Apr. 21, 2014
"Underlying the proposed regulation is the DOL's assumption that providers have 'specialized' knowledge enabling them to more easily locate fee information... Also underlying the proposed regulation is the assumption that a provider's specialized knowledge will reside in a single 'financial ... or similar professional' through whom the provider may quickly construct the guide for any given service.... Since these guides can 'make or break' the use of the exemption, it is hard to imagine that the guide will not require several levels of review at the business, compliance and legal level, as well as a review by 'plain English' editorial staff.... Even if one assumes that a guide would take a business person and a lawyer working together three to four hours per plan, at perhaps $1000 per plan, the cost of such a requirement would be 684,000 times $1000 ($684,000,000), or more than 17 times the benefit ($40,300,000) described in the cost analysis."
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