"[T]he threat of reporting [a delinquent Covered Service Provider (CSP) to EBSA] provides leverage to obtain accurate disclosures ... [A Responsible Plan Fiduciary (RPF)] that continues to utilize the services of a delinquent CSP after the 90-day grace period, loses the relief available under the special class exemption, and the ongoing relationships would almost certainly constitute a prohibited transaction.... [It's] clear the EBSA has launched an initiative to examine plan providers and this reporting requirement supports that initiative."  MORE >>