One of the many projects that the Department of Labor (DOL) is working on; gets us back to the Section 408(b)(2) disclosures.<\/p>\n
Shortly, the DOL may amend the disclosure regulations to require a guide or supplement should be issues to accompany the fee disclosures that service providers hand out to their plan sponsors.\u00a0 Apparently, the DOL thinks that the disclosures or multiple forms handed out to medium or small sized plans have been confusing.<\/p>\n
Of course they are, these plan provider disclosures were most likely written by lawyers whop get paid hourly to write documents in legalese and then get paid hourly to interpret these legalese documents. I know, I used to work for some of these firms.<\/p>\n
So if you are a plan provider, you may want to look at your current disclosures and see what\u2019s in easy to understand English and what\u2019s not. The guide that the DOL may require is probably some form of index that will allow plan sponsors to identify where the required fee disclosures are in the disclosures.<\/p>\n
I think that if your disclosures need some sort of map, then there is something clearly wrong. While we all need legalese to limit our liability, it\u2019s important that plan sponsor understand your fees, to allow yourself to be competitive in the marketplace because confused clients aren\u2019t particularly happy clients.<\/p>\n
If there is any guidance from the DOL on any guide requirements, I\u2019ll let you know.<\/p>\n
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