Bates & Company, Inc.
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AimPoint Pension
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Regional Vice President of Sales The Retirement Plan Company
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Compass
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Loan & Distribution Specialist AimPoint Pension
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Defined Benefit Combo Cash Balance Compliance Consultant Loren D. Stark Company (LDSCO)
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Year-End Stimulus Bill Includes ERISA Disclosure Requirements for Certain Group Health Plan Service Providers
Morgan Lewis [Guidance Overview] Jan. 12, 2021 "[T]he disclosure requirement is limited to brokers and consultants -- it does not apply, for example, to insurance providers or pharmacy benefit managers (PBMs).... Because plan sponsor payments are excluded from the definitions of 'direct compensation' and 'indirect compensation,' it would appear that a broker or consultant paid solely by the plan sponsor is not subject to this rule. However, if the broker or consultant is receiving 'indirect' compensation from other sources, such as an insurance company, then the rule may apply if that compensation reaches the $1,000 threshold." |
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