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- To steal a joke from Chris Rock, when I worked at a TPA as the lead ERISA attorney, I used to joke that if you wanted to hide something from one of our plan administrators, just put it in the plan document file. Nobody ever cracked one open. Why? Because someone had already plugged the plan specs into Relius, and that’s all anyone looked at. The problem, of course, was that the woman running the show back then was a complete buffoon. Things were constantly wrong — specs didn’t line up, operational errors piled up, and everyone assumed Relius was the gospel truth. Meanwhile, the plan document — the actual governing instrument under ERISA — sat ignored, like an unread instruction manual stuffed in a drawer. Here’s the point: plan specs are only as good as the plan document they’re based on. If they don’t match, you’re courting disaster. I’ve seen plan sponsors dragged into compliance nightmares, IRS corrections, and even litigation simply because the specs in the recordkeeping system didn’t mirror what was written in black and white. So, whether you’re a TPA, advisor, or plan sponsor, don’t treat the plan document like some dusty artifact. Specs, procedures, Relius entries, prototypes — all of it needs to reflect what’s actually in the governing document. Otherwise, you’re just building mistakes into the system and waiting for the IRS or DOL to find them. Trust me, when they do, you won’t be laughing at the Chris Rock joke anymore.
- If You Want to Hide Something, Put It in the Plan Document
- The Double-Edged Sword of Social Media
- The DOL’s Spring 2025 Regulatory Agenda: What Plan Providers Need to Know
- Home Depot Wins Forfeiture Fight: Another Court Shuts Down Fiduciary Breach Claims
Recent Comments
- John O'Reilly on You Might Be Gold, But They May Not See It
- Dale F. Smith on “Experienced” Plan Provider can mean a lot of things
- Steve on Make a sure a plan provider change is for the right reason and not to make someone $$$$$
- Dale F. Smith on Yale Law Professor scares 6K Plan Sponsors and everyone missed the point
- Sherry Gensemer on The High Fee Open MEP becomes a High Fee MEAP
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Monthly Archives: October 2025
To steal a joke from Chris Rock, when I worked at a TPA as the lead ERISA attorney, I used to joke that if you wanted to hide something from one of our plan administrators, just put it in the plan document file. Nobody ever cracked one open. Why? Because someone had already plugged the plan specs into Relius, and that’s all anyone looked at. The problem, of course, was that the woman running the show back then was a complete buffoon. Things were constantly wrong — specs didn’t line up, operational errors piled up, and everyone assumed Relius was the gospel truth. Meanwhile, the plan document — the actual governing instrument under ERISA — sat ignored, like an unread instruction manual stuffed in a drawer. Here’s the point: plan specs are only as good as the plan document they’re based on. If they don’t match, you’re courting disaster. I’ve seen plan sponsors dragged into compliance nightmares, IRS corrections, and even litigation simply because the specs in the recordkeeping system didn’t mirror what was written in black and white. So, whether you’re a TPA, advisor, or plan sponsor, don’t treat the plan document like some dusty artifact. Specs, procedures, Relius entries, prototypes — all of it needs to reflect what’s actually in the governing document. Otherwise, you’re just building mistakes into the system and waiting for the IRS or DOL to find them. Trust me, when they do, you won’t be laughing at the Chris Rock joke anymore.
To steal a joke from Chris Rock, when I worked at a TPA as the lead ERISA attorney, I used to joke that if you wanted to hide something from one of our plan administrators, just put it in the … Continue reading
Posted in Retirement Plans
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If You Want to Hide Something, Put It in the Plan Document
To steal a joke from Chris Rock, when I worked at a TPA as the lead ERISA attorney, I used to joke that if you wanted to hide something from one of our plan administrators, just put it in the … Continue reading
Posted in Retirement Plans
Leave a comment
The Double-Edged Sword of Social Media
The beauty of social media is that everyone has an opinion. The negative part of social media is that everyone has an opinion. Once upon a time, disagreements lived at the dinner table, in union halls, or on the floor … Continue reading
Posted in Retirement Plans
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The DOL’s Spring 2025 Regulatory Agenda: What Plan Providers Need to Know
The Department of Labor (DOL) has released its Spring 2025 regulatory agenda, and for those of us in the retirement plan industry, it reads like a greatest hits playlist — ESG, fiduciary rule, auto-portability, pharmacy benefit managers (PBMs), electronic disclosure, … Continue reading
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Home Depot Wins Forfeiture Fight: Another Court Shuts Down Fiduciary Breach Claims
Chalk up another win for plan fiduciaries in the ongoing wave of forfeiture reallocation suits — and this time, the plaintiffs didn’t even get the courtesy of a do-over. The Case Roughly a year ago, participant Guadalupe Cano sued Home … Continue reading
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Retirement Balances Hit Record Highs: Staying the Course Pays Off
According to Fidelity Investments’ latest Q2 2025 retirement analysis, retirement savers got some good news: average 401(k), 403(b), and IRA balances hit record highs. Despite the rocky market start this quarter, balances climbed: 401(k)s up 8%, 403(b)s up 9%, and … Continue reading
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Walking on Eggshells with Plan Sponsors
A long-time client of a financial advisor had a 401(k) plan sponsor that was quiet, easy to deal with, and, most importantly, loyal. Everything seemed smooth until the advisor’s new employee came on board. The new hire saw the plan … Continue reading
Posted in Retirement Plans
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