For nearly 40 years, ERISA has required retirement plan fiduciaries to ensure the reasonableness of service and investment fees paid by the plan. However, fee reasonableness has only recently grabbed headline attention due largely to the finalization of the 408(b)(2) regulations and the Missouri district court's decision in Tussey v. ABB, Inc. Despite the strength of its fee reasonableness standard, ERISA provides little practical guidance as to how and when plan fiduciaries should be making and documenting their fee reasonableness determinations. In this presentation, we provide a historical overview of the legislative, regulatory and judicial context surrounding this fundamental fiduciary duty; a look at recent Department of Labor regulatory examination activity centered on fee reasonableness; and a practical, step-by-step guide to meeting the fee reasonableness requirements.
Now that fee disclosures are being delivered to employers and participants each year, how do you fulfill your fiduciary duty to determine the reasonableness of plan fees and communicate the information to employees?
An effective way is with a documented fee review process. Check out our presentation from a recent learning symposium for plan fiduciaries.
HunterMaclean ERISA and employee benefits attorney Rebecca Sczepanski made this presentation at the 2015 Savannah Fiduciary Seminar. Her presentation covered a summary of the legal issues regarding fiduciary status, including how to identify ERISA and state law fiduciaries. She provided tips for avoiding or mitigating risks associated with defined plan fiduciary status as well as an update on major fiduciary litigation.
Rick Pummill - TRPC - Effective Plan Design and AdministrationDowney Brand LLP
In his presentation at the 2015 Savannah Fiduciary Seminar, Rick Pummill of The Retirement Plan Company presented on how to make 401(k) or Defined Contribution Plan operations more effective, from design tips to electronic delivery of disclosures.
Randall Webb - TJSDD - Common Pitfalls and Deficiencies Found in Plan AuditsDowney Brand LLP
At the 2015 Savannah Fiduciary Seminar, Randall Webb of TJS Deemer Dana presented the most common deficiencies identified during plan audits and how plan sponsors should correct those deficiencies going forward.
You're going to need a bigger boat
Held at the Heldrich in New Brunswick, New Jersey, this event marked the newest one-day event covering equity compensation and brought together professionals working in the equity compensation field from across North America. Event partners Rutgers' School of Management and Labour Relations, and the school's Executive and Professional Education (EPE) program modeled the event after the Annual CEP Symposium at Santa Clara University.
Featuring comments from Joe Purdy, CEP, Solium Jennifer Namazi, CEP, NASPP, Ben Needham, CEP, MindBody, and John Hammond, CEP, bendystraw
Now that fee disclosures are being delivered to employers and participants each year, how do you fulfill your fiduciary duty to determine the reasonableness of plan fees and communicate the information to employees?
An effective way is with a documented fee review process. Check out our presentation from a recent learning symposium for plan fiduciaries.
HunterMaclean ERISA and employee benefits attorney Rebecca Sczepanski made this presentation at the 2015 Savannah Fiduciary Seminar. Her presentation covered a summary of the legal issues regarding fiduciary status, including how to identify ERISA and state law fiduciaries. She provided tips for avoiding or mitigating risks associated with defined plan fiduciary status as well as an update on major fiduciary litigation.
Rick Pummill - TRPC - Effective Plan Design and AdministrationDowney Brand LLP
In his presentation at the 2015 Savannah Fiduciary Seminar, Rick Pummill of The Retirement Plan Company presented on how to make 401(k) or Defined Contribution Plan operations more effective, from design tips to electronic delivery of disclosures.
Randall Webb - TJSDD - Common Pitfalls and Deficiencies Found in Plan AuditsDowney Brand LLP
At the 2015 Savannah Fiduciary Seminar, Randall Webb of TJS Deemer Dana presented the most common deficiencies identified during plan audits and how plan sponsors should correct those deficiencies going forward.
You're going to need a bigger boat
Held at the Heldrich in New Brunswick, New Jersey, this event marked the newest one-day event covering equity compensation and brought together professionals working in the equity compensation field from across North America. Event partners Rutgers' School of Management and Labour Relations, and the school's Executive and Professional Education (EPE) program modeled the event after the Annual CEP Symposium at Santa Clara University.
Featuring comments from Joe Purdy, CEP, Solium Jennifer Namazi, CEP, NASPP, Ben Needham, CEP, MindBody, and John Hammond, CEP, bendystraw
The Bermuda EBS Technical Provisions PowerPoint presentation given by consulting actuary Chandu C. Patel, FCAS, MAAA at last week's CAMAR meeting is now available for viewing.
Whitepaper: Meeting Your ERISA Fiduciary ResponsibilitiesCBIZ, Inc.
This whitepaper discusses who is considered a "Fiduciary", what the significance of being a Fiduciary is and Fiduciary responsibility recommendations.
For more information, visit www.cbiz.com
In response to the 2008 financial crisis, regulators and investors put pressure on the FASB and IASB to develop models that would require financial institutions to recognize losses earlier in the credit cycle. Measuring credit loss on Pools of loans...
401(k) Advisors service model starts with a Fiduciary Fitness program, Including a Fiduciary Investment and plan review and providor benchmarking analysis. Our RFP and provider search process is second to none where we gather over 300 data points on each provider and provide a detailed breakdown of Fees, Fund performance, and service. Our propriatery investment scorecard system takes in to account, Investment style, risk, peer group ranking, and qualitative analysis to help plan sponsors provide the necessary investment due dilligence to satisfy their fiduciary compliance obligations.
•Gain an understanding of the CECL model and impact on the Allowance for Loan Losses calculation.
•Understand the potential impact of the CECL on Credit Union financial statements upon adoption.
•Understand the differences between the current allowance for loan losses accounting model and the proposed CECL model.
LIVE EVENT - 3rd Annual Fall Construction Risk Update - September 30Rea & Associates
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Winston & Strawn's Employee Benefits & Executive Compensation Practice hosted an eLunch to discuss key issues faced by plan sponsors during IRS and DOL audits of retirement plans. The most common problem areas identified by IRS and DOL agents were addressed, with practical tips for plan sponsors on how to establish and maintain internal controls to help avoid compliance errors. Topics included:
-The most significant issues DOL agents focus on during audits, including missing participants, late payroll deposits, and missed employee communications
-The most significant issues IRS agents focus on during audits, including definitions of compensation, age 70-1/2 distributions, employee eligibility requirements, and properly updated plan documents
-Steps employers can take in order to improve their internal controls for compliance with IRS and DOL requirements
Contact Winston & Strawn for more information about this presentation:
https://www.winston.com/en/thought-leadership/irs-and-dol-audit-issues-for-retirement-plans.html
The Bermuda EBS Technical Provisions PowerPoint presentation given by consulting actuary Chandu C. Patel, FCAS, MAAA at last week's CAMAR meeting is now available for viewing.
Whitepaper: Meeting Your ERISA Fiduciary ResponsibilitiesCBIZ, Inc.
This whitepaper discusses who is considered a "Fiduciary", what the significance of being a Fiduciary is and Fiduciary responsibility recommendations.
For more information, visit www.cbiz.com
In response to the 2008 financial crisis, regulators and investors put pressure on the FASB and IASB to develop models that would require financial institutions to recognize losses earlier in the credit cycle. Measuring credit loss on Pools of loans...
401(k) Advisors service model starts with a Fiduciary Fitness program, Including a Fiduciary Investment and plan review and providor benchmarking analysis. Our RFP and provider search process is second to none where we gather over 300 data points on each provider and provide a detailed breakdown of Fees, Fund performance, and service. Our propriatery investment scorecard system takes in to account, Investment style, risk, peer group ranking, and qualitative analysis to help plan sponsors provide the necessary investment due dilligence to satisfy their fiduciary compliance obligations.
•Gain an understanding of the CECL model and impact on the Allowance for Loan Losses calculation.
•Understand the potential impact of the CECL on Credit Union financial statements upon adoption.
•Understand the differences between the current allowance for loan losses accounting model and the proposed CECL model.
LIVE EVENT - 3rd Annual Fall Construction Risk Update - September 30Rea & Associates
If the last two years have taught us anything, it’s that you can never be too prepared. Rea & Associates is proud to present the 3rd Annual Fall Construction Risk Update event, jam packed with expert commentary and exclusive content for business owners in the construction industry. This year, we’re here to guide you through the changes 2021 brought to taxes, finances, liability, and more and give you a glimpse into future considerations for construction industry leaders.
Winston & Strawn's Employee Benefits & Executive Compensation Practice hosted an eLunch to discuss key issues faced by plan sponsors during IRS and DOL audits of retirement plans. The most common problem areas identified by IRS and DOL agents were addressed, with practical tips for plan sponsors on how to establish and maintain internal controls to help avoid compliance errors. Topics included:
-The most significant issues DOL agents focus on during audits, including missing participants, late payroll deposits, and missed employee communications
-The most significant issues IRS agents focus on during audits, including definitions of compensation, age 70-1/2 distributions, employee eligibility requirements, and properly updated plan documents
-Steps employers can take in order to improve their internal controls for compliance with IRS and DOL requirements
Contact Winston & Strawn for more information about this presentation:
https://www.winston.com/en/thought-leadership/irs-and-dol-audit-issues-for-retirement-plans.html
Each year Albuquerque participates in Bike to Work Day (BTWD), which celebrates and encourages bicycle
transportation. In 2016, the Mid-Region Council of Governments (MRCOG), in collaboration with others, developed and distributed a survey to BTWD participants to build a better understanding of bicyclists needs, collect general perceptions about bicycling in the greater Albuquerque area, and identify targeted actions to make Albuquerque more bicycle friendly.
There was an overall perception that Albuquerque is improving bicycle friendliness. Comments underscored the impact
of dedicated bikeways and trails. After the 2016 BTWD event, several significant bikeway projects were completed,
which will provide an interesting comparison with future survey efforts. The survey results also helped to see concerns
such as people’s behavior on roadways and take a deeper look at key elements to improve infrastructure as well as the
BTWD event itself.
Tech & Transit Oriented Development - The New TODLisa Nisenson
Shared use mobility & autonomous vehicles are reshaping access to transit. This presentation shows how walking, biking & transit are still transportation's backbone, and how AVs + active form new opportunities for cities of all sizes.
Under ERISA Section 408(b)(2), retirement plan fees must be reasonable in light of the services being rendered. Retirement plan fees are also a hot target in the courts, most notably with last year's Tussey vs. ABB, Inc. decision. In this presentation, we discuss just what the reasonableness standard means for today's retirement plan sponsors, and an action plan for employers.
Retirement plan sponsors have a multitude of recordkeeping vendors from which to choose in assisting them with plan administration, compliance and participant education. Each potential vendor espouses a value proposition, which must be weighed in relationship to the plan’s needs, goals and objectives to determine if that particular vendor is a suitable fit.
While conducting a vendor search may seem burdensome, the benefits associated with the search make it more than worthwhile. By conducting a vendor search, plan sponsors can satisfy certain fiduciary responsibilities and optimize the plan’s benefit to its participants. Moreover, the perceived vendor search burden is significantly eased when a few simple best practices are followed.
In this presentation, we explore the benefits and best practices associated with conducting a vendor search. It concludes with three case studies that demonstrate the positive results and improvements that plan sponsors might expect from a well executed vendor search.
Dynamic Changes Occurring: OMB's Uniform Grant GuidanceStreamLinkSoftware
At this year’s National Association of State Auditors, Comptrollers and Treasurers (NASACT) Annual Conference in Chicago, Illinois, StreamLink Software CEO, Adam Roth, and partner at accounting firm Plante Moran, Michelle Watterworth, presented on UGG’s impact on grant administration and audits.
ASC 606: Accounting for Contracts with Customers, transforms the way all companies recognize revenue for the sale of goods and services. The implementation of the new standard impacts processes, people and systems for all sectors of the organization from the accounting and finance team to legal and human resources.
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Looking for an Executive Compensation Checklist for your Credit Union? This presentation serves as a valuable tool for new and experienced board members in pinning down the latest information on new regulations and compensation philosophies associated with creating a successful executive compensation plan. For more info, visit: www.nafcu.org/bfb
Retirement Plans: Managing Your Fiduciary ResponsibilitySecureDocs
http://www.securedocs.com - Protecting the financial viability of a company is a heavy undertaking. As a trusted advisor to the business as an entity as well as your colleagues, you are expected to use your expertise to determine best practices to keep everyone’s profits and retirement plan savings afloat. It is important that you use a disciplined process to help manage your fiduciary responsibility.
This presentation covers a series of new and important information regarding your role as a fiduciary.
View the presentation to learn about:
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-401K, IRS and Department of Labor (DOL) audit planning.
Employee Benefits and Human Resources: The Year in Review and a Look at What’...Winston & Strawn LLP
2016 included significant legislative, regulatory, enforcement, and case law developments in the employee benefits and human resources area, and 2017 promises to be a year of change. Therefore, it is important to stay up-to-date on the latest legal developments, threats, and best practices.
Steve Flores and Christine Matott from our Employee Benefits & Executive Compensation Practice, Rob Newman and Alessandra Swanson from our Privacy & Data Security Practice, and Cardelle Spangler from our Labor & Employment Practice, reviewed important compliance deadlines and areas of potential risk. The discussion examined the following important areas:
Significant plan fiduciary litigation
DOL Conflict of Interest Rules
Affordable Care Act developments, including reporting and enforcement
Updates on HIPAA enforcement, including the latest on OCR’s audits, recently released guidance, and case settlements
Recent changes to employee privacy laws, including state breach notification laws and EU data transfer laws
New overtime rules, EEOC LGBT protections, and ban the box rules
The TPA works with the plan sponsor to ensure the ongoing accuracy of the plan, minimize the time the plan sponsor has to spend on plan oversight, meet service and compliance deadlines, and coordinate with all parties.
Practical Guidance on Securities Offerings (including High Yield and Initial ...Winston & Strawn LLP
The third installment of The Real Deal, “Practical Guidance on Securities and Initial Public Offerings in a Changing Environment,” was held on March 18, 2014. The Real Deal is a webinar series addressing current trends, challenges, and legal topics pertinent to M&A and securities professionals.
Winston & Strawn partners Jim Junewicz, Cabell Morris, and Karen Weber participated in an interactive webinar focused on what you need to know about the latest developments in securities offerings, including high yield offerings and IPOs.
Retirement Plans Under Attack by Plan Participants and Government Agencies: A...Human Capital Media
Recently, the courts have made it easier for retirement plan participants to sue plan fiduciaries on grounds ranging from inadequate plan investments and excessive plan fees or misstatements regarding plan benefits. Both the IRS and DOL have been aggressively auditing plans and holding employers’ feet to the fire when perceived violations are found. Employers now, more than ever, must take seriously their role as the stewards of their 401(k) plans. In this session, we will discuss best practices for fiduciary governance especially in light of the DOL’s new fiduciary rules, and specific steps that can be taken to protect plan fiduciaries. We will also discuss areas of concern to employers in their role as plan administrators and the best way to protect plans from administrative miscues.
INSZoom Immigration Conference 2017 – The sea of global compensation and soci...INSZoom
Travelling on an assignment from the home country to a host country or from high-cost to a low-cost economy? The expat will cross several compensation models, treaties and agreements. How do you stay compliant? This session gives you an upshot!
Billing by the hour, though seemingly more profitable for law firms, presents a compounding conflict of interest between an attorney and their clients. For this reason, many lawyers celebrate the transition to a packaged flat-fee billing model — introducing predictability, incentive to make progress, and even a competitive advantage for their firms.
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Even with the most earnest intentions, mistakes inside of a retirement plan will most likely happen from time to time. Plan sponsors can take solace in knowing that there is a corrective solution for nearly every compliance problem. Knowing how to correct a plan error will help plan sponsors act swiftly so as not to ripen the problem should one occur. It can also help save the plan sponsor money. In this program, Multnomah Group will provide an overview of the correction programs available through both the Internal Revenue Service (for Internal Revenue Code issues) and the Department of Labor (for issues under the Employee Retirement Income Security Act).
The legislative landscape in which retirement plans must operate is constantly evolving to meet the need for an appropriate level of industry regulation. Legislative and regulatory activity during 2013 to date has created numerous opportunities and challenges that retirement plan sponsors must address. In this program, Erik Daley, CFA, will provide an overview of this year's legislative and regulatory developments and focus on practical, consultative tips on how they might apply to your retirement plan.
The past 30 years has born witness to the collapse of the private pension system with for-profit employers, tax-exempt entities and now the governmental sponsors replacing defined benefit pension programs with defined contribution plans. This practice spawned a well-documented transfer of investment and funding risk from employer to employee. Now, most defined contribution plans render the employee the sole decision maker on the four factors that determine an employee's ability to retire successfully: contribution rate, investment strategy/return, time horizon, and spending needs in retirement.<br /><br /> In this presentation we will address what employers can do to help employees meet the demands of the new retirement plan era.
Retirement plan fiduciaries have a responsibility for the prudent selection and monitoring of plan investments. If your investment selection decisions are based solely on investment style, fees and historical returns, you may be missing the larger picture. In this presentation, we present a rigorous, multi-step process for selecting investment managers to serve your plan’s and participant’s needs. Using a use case scenario, we will demonstrate how to define the “Investment Universe”, the use and limitations of quantitative analysis, conducting proper qualitative due diligence, and the selection of a prudent investment for a participant-directed defined contribution retirement plan.
Target date funds are quickly becoming the dominant investment option within many defined contribution retirement plans. Regulators have taken notice with the Department of Labor (DOL) contemplating new disclosure requirements for plans offering target date funds.
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3.0 Project 2_ Developing My Brand Identity Kit.pptxtanyjahb
A personal brand exploration presentation summarizes an individual's unique qualities and goals, covering strengths, values, passions, and target audience. It helps individuals understand what makes them stand out, their desired image, and how they aim to achieve it.
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2. Gina Gurgiolo, JD, LL.M
Gina Gurgiolo is a Senior Consultant for the Multnomah Group responsible for
the firm’s ERISA technical and recordkeeping vendor search consulting
services. Gina consults with plan sponsors on plan design, fiduciary
governance, and vendor fees/services.
Prior to joining the Multnomah Group in 2010, Gina managed the product
portfolio for a national retirement services firm and directed the firm’s plan
administration unit serving its largest clients. Prior to that, Gina managed the
retirement plan compliance and regulatory policy functions at another national
retirement services firm.
Gina earned her JD from the University of Pittsburgh and her LL.M in Taxation
with an emphasis in retirement plan and executive compensation law from the
University of Denver. Gina is a member of the Portland Chapter of the Western
Pension & Benefits Council, where she has been a conference speaker.
2 Best Practices for Ensuring Retirement Plan Fee Reasonableness
3. Agenda
• Context and Historical Overview
• Legislative
• Regulatory
• Judicial
• Preparing for a DOL Audit
• Most frequently requested information
• Case study
• Step-by-Step Guide to Fee Reasonableness
• Fee reasonableness “to-dos”
3 Best Practices for Ensuring Retirement Plan Fee Reasonableness
4. Context & Historical Overview
What is “reasonable”?
• Intangible no bright line
• Agreeable to sound judgment or logic
• That which is appropriate for a particular situation
• Not excessive relative to circumstances
Determining reasonableness requires comparison of alternatives and
evaluation of processes used
Under ERISA section 408(b)(2), retirement plan fees must be reasonable in
light of the services being rendered
• But, no specific codified definition of what constitutes fee reasonableness
per se
• Impossible to be absolute about reasonableness determinations
• Follow prudent process that contemplates alternatives
- Using prudent process to negotiate/compare fees/services promotes improved participant
outcomes
• Must know and understand applicable fees to determine reasonableness
• Where can plan sponsors find comprehensive fee information?
4 Best Practices for Ensuring Retirement Plan Fee Reasonableness
5. Context & Historical Overview
Regulations under ERISA section 408(b)(2) require annual covered service
provider-to-employer disclosure of fees
• First-year deadline July 1, 2012
• Empower plan sponsors to better comply with the fee reasonableness
standard under ERISA section 408(b)(2)
• Must terminate non-compliant covered service providers
1974: ERISA is enacted, including section 408(b)(2)
2007: Proposed fee disclosure regulations are issued
2009: Revised 2009 Form 5500 Schedule C requests more fee
information than ever
2010-2012: Fee disclosure regulations are finalized and become effective;
DOL investigation and enforcement activity increases
2012: First retirement plan fee class action suit decided (Tussey, et al. v.
ABB, Inc.); similar litigation looming
5 Best Practices for Ensuring Retirement Plan Fee Reasonableness
6. Context & Historical Overview
Tussey, et al. v. ABB, Inc.
• Federal district court in Missouri; appeal to Eighth Circuit Court of Appeals?
• Case originated in 2006 from 15 separate complaints filed by ABB, Inc.
employees
• Separate actions certified as a class in 2007 ? first instance of a plan fee
related class action suit
• Plaintiffs awarded $37M because:
• 401(k) plan fees subsidize corporate services benefiting executives
• A lower cost share class of investments was available, but was not being used
• Policies/process not being followed
• Failure to pass excess investment revenue sharing back to the plan
• Reaffirmed fee reasonableness standards under ERISA section 408(b)(2)
• Similar litigation is looming
• At issue is whether the plan fiduciary used a prudent reasonableness evaluation
process, had the right level of expert assistance, and/or documented the process
steps
• No requirement to choose lowest-cost services and investment options, just act
prudently and pay reasonable fees
6 Best Practices for Ensuring Retirement Plan Fee Reasonableness
7. Preparing for a DOL Audit
• The DOL has the responsibility to enforce ERISA’s standards, including
ensuring fee reasonableness
• DOL investigation/enforcement activity is on the rise since 408(b)(2)
regulations were proposed and fee litigation trend began
• How are plans are selected for investigation?:
• Randomly
• For cause/“red flag”
• 5500 reports late deferral remittance
• Independent auditor issues qualified report
• Participant complaints
• Up to 6-year investigation period
7 Best Practices for Ensuring Retirement Plan Fee Reasonableness
8. Preparing for a DOL Audit
What will DOL request?
• Service provider information
• Accountants, actuaries, administrators, attorneys, brokers, consultants, contract
administrators, insurance companies, investment advisors, investment managers,
recordkeepers, TPAs, valuation appraisers
• Service agreements/contracts
• Describing services, duties, obligations, responsibilities, fee / compensation /
commission schedule
• Service provider reports
• Investment performance reports, audit reports, actuarial reports
• Fee assessment and payment documents
• Invoices, cancelled checks
• Service provider selection documents
• RFP, proposals, comparative evaluation analysis, negotiation communications,
assessment of fees relative to quality of service
• Investment documents
• Revenue sharing information, share class identification, stable value fund
illiquidity/redemption or surrender fees
• Rebate information
• 12-b-1 fees, sub-transfer account fees, marketing/services fees, expense
reimbursement account deposits
8 Best Practices for Ensuring Retirement Plan Fee Reasonableness
9. DOL Audit Case Study: Fee Reasonableness
Context: Response / Outcomes:
• 403(b) Plan Sponsor • Submitted requested information,
• 2012 investigation including annual fee benchmarking,
search effort documentation, fee
• January 1, 2007 to present
policy statement
investigation period
• No requested follow-up information
regarding the DOL’s evaluation of
fee reasonableness
9 Best Practices for Ensuring Retirement Plan Fee Reasonableness
10. Step-by-Step Guide to Fee Reasonableness
Fee reasonableness to-do list:
Maintain a Fee Policy Statement and other proper fiduciary governance
documents (e.g. Committee Charter, Investment Policy Statement)
• List applicable fees under the Plan
• State whether the employer, forfeiture account, or participants pay the fees
• State intent to ensure fee reasonableness
Timely receive and review/analyze annual covered service provider-to-
employer fee disclosure notice
• Know your plan’s fees and understand how they work
• Follow-up with questions as needed
Benchmark recordkeeper’s fees to the market annually
• Plan is not required to select the recordkeeper with the lowest fees
• Fees must be reasonable in light of services rendered
• Negotiate incumbent recordkeeper’s fees if they are higher than benchmarked
range
10 Best Practices for Ensuring Retirement Plan Fee Reasonableness
11. Step-by-Step Guide to Fee Reasonableness
Fee reasonableness to-do list (cont.):
Request lowest-cost share class of investment options
• Document the process and decision whether to implement
Issue request for bid or request for proposal to the prequalified recordkeeper
universe every 5-6 years
• Coincides with typical statutes of limitations
• Document the effort, resulting decisions and rationale
Gather appropriate documentation in preparation for DOL investigation
• Expect an audit and prepare to avoid scramble for documents (typically, 15-day
response period allowed)
• Organize service, investment and fee information requested in the event of an
investigation
11 Best Practices for Ensuring Retirement Plan Fee Reasonableness
12. Disclosures
Multnomah Group, Inc. is an Oregon corporation and SEC registered
investment adviser.
Any information and materials contained herein or on our website are provided
“as is” for general informational purposes only. It is not intended to be
comprehensive for any particular subject. While Multnomah Group takes pride
in providing accurate and up to date information, we do not represent,
guarantee, or provide any warranties (either express or implied) regarding the
completeness, accuracy, or currency of information or its suitability for any
particular purpose.
Receipt of information or materials provided herein or on our website does not
create an adviser-client relationship between Multnomah Group and you.
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12 Best Practices for Ensuring Retirement Plan Fee Reasonableness