On March 18, 2015, the Department of Labor (DOL) issued a direct final rule that revises the annual disclosure requirement in the participant-level fee disclosure regulations under ERISA Section 404(a). The guidance provides...more
U.S. Department of Labor (DOL) regulations require 401(k) plan fiduciaries to provide plan participants with a detailed disclosure statement about the plan’s designated investment alternatives, prior to initial enrollment and...more
In September, state securities regulators formed a working group aiming to make broker-dealers’ disclosures about their fees more clear, accessible, and useful to investors in comparing different firms’ charges. The group...more
In This Issue:
- Pearls of "Wisdom" for 401(k) Plan Providers.
- Bells and whistles not being used is worse than having no bells and whistles.
- The Fallout from Fee Disclosure continues.
- As a 401(k)...more
On November 18, 2014, the CFPB staff and Federal Reserve Board co-hosted a webinar that addressed questions about the Final TILA-RESPA Integrated Disclosure Rule that will be effective for applications received by creditors...more
When I was fresh out of school and started my first job working for a third party administration (TPA), the paralegal that I was working with told me her experience with the retirement plan business that was pre-ERISA. Marge...more
On September 19, 2014, the Supreme Court of Canada released a trilogy of decisions examining the standing of representative plaintiffs and the availability of consumer protection legislation in the class action context....more
When I was a child, I remember bringing the soundtrack to Saturday Night Fever for my first grade class’ Chanukah party (I went to a Jewish day school). To this day, I still don’t how to operate a record player. Around the...more
The George Clooney-Brad Pitt trilogy of heist films known as Ocean’s Eleven, Ocean’s Twelve, and Ocean’s Thirteen were remembered for their twist endings, stylish pacing, and lightheartedness. Since the Ocean gang were...more
Plan Sponsors' Misconceptions About Retirement Plan Fee Disclosure.
There are many.
To me, there is no greater television show than Seinfeld because it's timeless and there is something about each episode that...more
There has been a tremendous amount of focus on participant-assessed fees in 401(k) and 403(b) plans over the last couple of years. This has come about, in part, because of lawsuits and the Department of Labor (DOL)...more
I talk to a lot of advisors and I have many advisor clients around the country and one of the things that I keep on hearing is that even with fee disclosure regulations almost 2 years later, it is still difficult to get...more
The SEC settled administrative proceedings against Transamerica Financial Advisors, Inc. (the “Adviser”) over its failure to grant advisory fee breakpoint discounts to certain advisory clients based on the aggregation of...more
On April 9, 2014, the Centers for Medicare and Medicaid Services (“CMS”) released the Medicare Provider Utilization and Payment Data: Physician and Other Supplier Public Use File (the “Data File”). The Data File contains...more
One of my favorite movies of all time is The Deer Hunter. It’s a story about the Vietnam War and the post-traumatic stress disorder a group of friends from Western Pennsylvania who were drafted together and fought alongside...more
Despite the CFPB’s plans to issue a proposed regulation concerning prepaid cards this spring, Senator Mark Warner has introduced a bill (S. 1903 ) that would require new disclosures for prepaid cards. The bill, entitled the...more
Whoever said that there is no such thing as a dumb question obviously wasn’t in attendance at my Global History class in high school when someone asked whether it was true that if you take a picture of an Amish person, the...more
What was good yesterday might not be a good today. Asbestos was a great fireproof building material until it was found to cause asbestosis and malignant mesothelioma Thalidomide was a great drug for morning sickness until it...more
When my wife and I bought our house, there were quite a few things that the previous owner forgot to tell us such as the fact they never bothered to pull the pipes from the dental office run by a previous owner 20 years...more
This update is intended as a general overview, targeted specifically at claims officers and underwriters of insurers of professionals required to comply with the Future of Financial Advice (FOFA) reforms.
In 1994. H. Wayne Huzienga sold Blockbuster Video to Viacom for $8.4 billion. At its peak, there were 9,000 stores. Dish Network who bought Blockbuster a few years ago for $320 million, just announced the closing of the last...more
On July 22, the Department of Labor (DOL) issued Field Assistance Bulletin No. 2013-02 (FAB 2013-02) that extended the deadline for plan sponsors to provide 2013 annual participant fee disclosures by six months. ...more
The United States Department of Labor (DOL) recently issued guidance that gives administrators of defined contribution plans a one-time opportunity to reset their deadline for providing participants with the plan’s required...more
Earlier this month we reminded you that plan administrators of participant-directed ERISA defined contribution retirement plans (e.g., 401(k) plans, 403(b) plans, profit sharing plans and money purchase plans) had to...more
The U.S. Department of Labor (DOL) released Field Assistance Bulletin (FAB) 2013-02 on July 22, 2013, which provides plan administrators of individual account plans with participant-directed investments (such as 401(k) and...more
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