Fees not usually included in annual pricing
- ERISA Bond
- PPA Plan Restatement needing to be done before April 30, 2016
- Advisor fees are shown in proposal and differ by advisor.
- Plans with over 100 eligible need to be audited but outside firm.
ERISA Bond – Employee Benefits Security Administration issues guidance on fidelity bonding for employee benefits.
Persons handling plan funds or other plan property generally must be covered by a fidelity bond to protect the plan against loss resulting from fraud and dishonesty by those covered by the bond.
Washington – The U.S. Department of Labor’s Employee Benefits Security Administration (EBSA) today released Field Assistance Bulletin (FAB) 2008-04, which provides guidance to the agency’s national and regional offices on the fidelity bonding requirements under section 412 of the Employee Retirement Income Security Act (ERISA).
Section 412 of ERISA requires all persons, including fiduciaries, who handle funds or other property of an employee benefit plan (otherwise referred to as plan officials) to be bonded in accordance with section 412 and the department’s regulations unless they are covered by an exemption. Each plan official is required to be bonded for at least 10% of the amount he or she handles, but in no event less than $1,000. The maximum bond amount required under section 412 with regard to any one plan is $500,000 per plan official, or $1 million per plan official in the case of a plan that holds employer securities.
EBSA investigators frequently confront fidelity bonding questions during their examinations of ERISA plans. FAB 2008-04 was developed to address these issues and is presented in a question-and-answer format consisting of 42 frequently asked questions (FAQs). The guidance in the FAB covers a variety of issues related to compliance with ERISA’s fidelity bonding requirements, including, among other things: whether a bond may use an omnibus clause to name insured plans; how to calculate the bond amount when multiple plans are covered under a single bond; whether the $1 million bond maximum applies in the case of plans that hold employer securities solely as a result of investments in pooled investment funds; and whether third party service providers are subject to the bonding requirements if they handle plan funds.
PPA Restatement – New Two-Year Period to Adopt Restated Pre-approved DC Plans
April 30, 2016, is the date by which employers using pre-approved defined contribution plan documents must adopt plan documents restated for the 2010 Cumulative List (the “PPA restatement”) (Announcement 2014-16). Most opinion and advisory letters for the latest round of pre-approved defined contribution plans were issued on March 31, 2014.
Determination letters for adopting employers
Most employers do not need to apply for a separate IRS determination letter for a pre-approved plan. Applications for individual determination letters for pre-approved defined contribution plans are due by April 30, 2016, in the limited circumstances when an individual letter is appropriate.
M&P plans – An employer who adopts a master & prototype plan (standardized or non-standardized) may not apply for its own determination letter on Form 5307. Instead, the employer should rely on the approval letter issued to the plan sponsor.
VS plans – An adopting employer who made limited modifications to its volume submitter plan may apply for a determination letter on Form 5307, Application for Determination for Adopters of Modified Volume Submitter Plans (instructions). If the modifications are extensive, causing the plan to be treated as an individually designed plan, the employer must instead file Form 5300, Application for Determination for Employee Benefit Plan.
Each advisor should be outlining what fees are being charged for which services. The plan sponsor is responsible to make sure these fees are benchmarked against other advisor fees foe similar size plans.The fees can be a flat dollar amount billed to plan sponsor or a fee against assets in the plan collected by the recordkeeper and forwarded to the advisors firm.
Plans with over 100 participants are subject to annual audit. Details here.
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