"Disqualified QPAMs must indemnify plan clients against losses resulting from the QPAM's disqualification and implement a one-year transition period to help plans mitigate disruptions from changing advisors, but QPAM management agreements need not be amended to include these terms."  MORE >>

"Significant changes ... [1] New registration requirement.... [2] Increases to assets under management and equity ownership thresholds.... [3] Recordkeeping requirement.... [4] Exclusive authority requirement.... [5] Prohibited misconduct.... [6] Notice to the DOL.... [7] One-year transition period.... [8] Application for individual exemptive relief."  MORE >>

"Fortunately, no immediate action is required of plan fiduciaries as a result of the final QPAM amendment with respect to any existing written management agreements with their QPAMs. While the proposed QPAM amendment previously issued by DOL would have required all written management agreements between QPAMs and plan investors to be amended to include specific indemnities triggered upon the investment manager's violation of laws or failing to qualify as a QPAM, the final amendment dropped this requirement."  MORE >>

"The key innovation of a PEP ... is that it is sponsored not by the employer but by a professional third-party provider [PPP] ... who assumes rather broad statutory fiduciary responsibilities under ERISA.... While all kinds and sizes of businesses may participate, each PPP is likely to have its own acceptance criteria, PEP features, and operational rules.... [E]mployers need to understand what a PEP can do for them and what remains the employer's responsibility."  MORE >>

"Target date funds are the QDIA in 86.1% of plans, and 92.9% in plans with more than 5,000 participants ... Target date offerings ... are now estimated to make up over 40% of the assets in 401(k)s.... Collective Investment Trust (CIT) vehicles have also continued to gain traction ... A handful of large off-the-shelf target date providers have launched a personalized solution in 2023 or have announced their intent to roll one out in the near-term ... Availability of managed accounts has increased from 30% of plans in 2018 to 41% of plans in 2022."  MORE >>

"To address the rising U.S. retiree population, some target-date fund (TDF) providers are now integrating annuities in their offerings to combat longevity risk and provide a stream of guaranteed income -- but these vehicles may not suit all investors[.]"  MORE >>

"If you choose to offer 401(k) loans, here are a few best practices to keep in mind: [1] Provide education on your plan offerings, including the ins and outs of 401(k) loans.... [2] You may not want to encourage employees to take loans.... [3] Make sure your plan offers easy ways to make payments, such as electronic payments via ACH."  MORE >>

"Get started by understanding your audience.... Build trust with frequent direct communications.... Measure effectiveness.... Implement modern communication techniques.... Use the team approach"  MORE >>

"If an employer realizes that it has not filed a Top Hat Statement when required, it may correct this failure using the DOL's Delinquent Filer Voluntary Compliance Program (DFVC Program).... [T]he employer must submit the late filing and a $750 user fee ... The $750 user fee applies regardless of the number of plans or the degree of lateness."  MORE >>

"Most CFOs are in the low- to mid-six-figure range for salary bands, with nearly three-quarters (73%) reporting they're set to earn between $201k-400k this year.... In 2021, 35% of CFOs said they earned between $151k-200k, a figure now reported by less than a quarter (17%). Instead, the number of CFOs earning over $250k has risen dramatically; 23% earn between $201k-250k and 22% earn $251k-300k. The most common salary band, between $301-400k, is earned by nearly three in 10 (28%) CFOs. In 2021, barely 10% received this type of compensation."  MORE >>