Operating in compliance. understanding irs and dol audit hot button issues and how to address them 9-20-18 ce

OppenheimerFunds is not undertaking to provide impartial investment advice
or to provide advice in a fiduciary capacity.
Operating in Compliance
VP and Senior Associate General Counsel
OppenheimerFunds
Understanding IRS & DOL Audit Hot-button Issues & How
Plan Sponsors Can Address Them
The financial advisor indicated above is not employed by OppenheimerFunds, Inc., or any subsidiary and his or her firm are not subsidiaries of OppenheimerFunds, Inc. Products
offered through OppenheimerFunds.

2
Agenda
ERISA is a highly complex area of law. The information contained in this material is strictly educational in nature and is not intended as
legal advice. Clients are strongly encouraged to obtain legal advice from a qualified expert.
IRS & DOL enforcement update
IRS & DOL audit “hot buttons” & case studies
401(k) plan check-up tools
Support network
Litigation update

What are your ERISA Fiduciary
responsibilities?

4
• Acting solely in the best interests of the plan participants (and their beneficiaries)
• Carrying out duties prudently
• Diversifying investments
• Following the terms of the plan documents
• Paying only reasonable plan expenses
• Monitoring for prohibited transactions
• Responding to inquiries
• Being “bonded” (Fidelity Bonds)
What Are A Plan Sponsor’s Fiduciary
Responsibilities?

5
Who Is a Fiduciary?
Fiduciary Roles and Responsibilities
Employer Every plan must have at least one fiduciary
Trustee Plan assets must be held in a trust or in a custodial account unless the plan is
funded exclusively with insurance contracts
Plan Administrator
(ERISA 3(16))
Plan sponsor is typically named the ERISA 3(16) plan administrator
Responsible for the day-to-day administrative decisions. The Plan Administrator
has the following primary responsibilities:
• Ensure all filings with the federal government (such as Form 5500) are timely
submitted
• Make important disclosures to plan participants
• Hire service providers if no other fiduciary has that responsibility
• Fulfill fiduciary responsibilities as set forth in plan documents
• Maintain/oversee day-to-day plan operations

6
Who Is a Fiduciary?
Fiduciary Roles and Responsibilities
Investment Adviser (ERISA
3(21))
Investment adviser who serves as a fiduciary investment adviser under
ERISA 3(21). The Plan sponsor shares fiduciary responsibility for plan
investment decisions with the Investment adviser.
Investment Manager (3(38)) “Investment Manager” takes full discretionary responsibility for
selecting and monitoring plan investments

7
• Fiduciaries can be personally liable for plan losses
• Fiduciaries may be responsible for co-fiduciary breaches
• Section 405(a) of ERISA provides that a fiduciary of a plan may be liable for a breach of fiduciary
responsibility committed by another fiduciary of the plan:
• (1) if he knowingly participates in, or knowingly undertakes to conceal a breach
• (2) enables another fiduciary to commit a breach
• (3) if he has knowledge of the breach and fails to make reasonable efforts under the
circumstances to remedy the breach.
What Happens if I Don’t Meet My Fiduciary
Responsibilities?

8
IRS (Internal Revenue Service)
Internal Revenue Code
DOL (Department of Labor)
ERISA
Focus
• Fiduciary rules
• Participant protections
Enforcement Framework
Focus
• Tax laws & regulations
• Plan documents

9
Oversees enforcement of ERISA
• Fiduciary standards of conduct
• Fee transparency
• Conflicts of interest
• Participant protections
Enforcement projects
• Employee Contributions Initiative
• Major Case Enforcement
• Contributory Plans Criminal Project
• Plan Investment Conflicts Project
The DOL – Employee Benefits Security
Administration (EBSA)

10
The DOL – Enforcement Results
$777.5 million paid to
plans, participants &
beneficiaries
• $352.0 million – plan assets
restored/benefits recovered
• $9.5 million – Voluntary
Fiduciary Correction
program
2016 fiscal year
enforcement results
2,002 civil
investigations
333 criminal
investigations
Source: Department of Labor Enforcement Results Fact Sheet Fiscal Year 2016, https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-
center/fact-sheets/ebsa-monetary-results.pdf

11
Oversees compliance with tax laws
• Contributions
• Nondiscrimination testing
• Distributions
• Plan documents
Enforcement
• Plan audits
• Plan document reviews
• Voluntary compliance programs
Reports results – EP Compliance Trends
and Tips
IRS – Employee Plans (EP)
http://www.irs.gov/Retirement-Plans/EP-Compliance-Trends-and-Tips

13
Develops projects on areas of
noncompliance
Conducts compliance checks through
correspondence or telephone
Saves plan sponsor time & money
IRS – EP Compliance Unit
To date
• 70 projects completed
• 41,000 compliance checks
https://www.irs.gov/retirement-plans/employee-plans-compliance-unit-epcu

IRS & DOL Audit “Hot Buttons”
& Case Studies

15
Common Plan Failures
IRS Audit “Hot Buttons”
Failure to timely update plan documents
Failure to operate the plan in accordance with plan terms
• Compensation definition
• Matching contributions
• ADP/ACP nondiscrimination tests
• Eligible employees
• IRC §402(g) deferral limit
• Deferral deposits
• Hardship distributions
• Loans
Source: IRS 401(k) Plan Fix-It Guide, Aug. 27, 2017

16
Written plan document required for tax-qualified
retirement plan
Plan sponsors must amend for required
amendments
Source: Christy & Swan Profit Sharing Plan v. Commissioner of IRS, T.C. Memo 2001-62 (Mar. 15, 2011)
Plan Documents & Amendments
Failure to amend plan document
can result in
• Plan is retroactively disqualified
• Tax deductions disallowed
• Participants’ plan balances are taxable

17
IRS Revenue Procedure 2016-51
Employee Plans Compliance Resolution System
(EPCRS)
Voluntary Correction Program
(VCP)
Employer initiated, IRS
submission
Reduced fee based on number of
participants
Operational, document,
demographic, & employer
eligibility errors
Audit Closing Agreement
Program (Audit CAP)
IRS initiated Penalty based on various factors Errors discovered under IRS
audit
Self-Correction Program (SCP) Employer initiated, no IRS
involvement
No fee Operational errors
PROCESS FEE
TYPES OF
ERRORS

18
Late PPA Restatement Correction Options
Corrections options for plans that missed restatement deadline
Plan sponsor submits under VCP
• User fee applicable, dependent on plan size
• VCP submission kit available from IRS
Document sponsor submits request for “umbrella” closing agreement
• $10,000 fee for first 20 plans
Pre-approved defined
contribution plans
6-year restatement cycles
PPA restatement
deadline
April 30, 2016
Sources: IRS website, Voluntary Correction Program (VCP) – General Description, September 27, 2017, https://www.irs.gov/retirement-plans/voluntary-correction-
program-general-description; New Program Allows Providers of Pre-Approved Plan to Correct Missed Deadlines, February 17, 2017, https://www.irs.gov/retirement-
plans/new-program-allows-providers-of-pre-approved-plan-to-correct-missed-deadlines

19
Hypothetical Case Study: Facts
Employer D 401(k) plan
• 8 participants
• Plan operates on a calendar-year basis
• January 1 & July 1 entry dates
Note: The persons portrayed in this example are fictional. This material does not constitute a recommendation as to the suitability of any investment for any person or
persons having circumstances similar to those portrayed and a financial advisor should be consulted.
Eligible Participants Excluded
Employer matching contribution
• 50% matching contribution on
deferrals up to 10% of compensation
Employee Jack
• Should have been given the opportunity to make elective deferrals on January 1, 2016
• Was not provided the deferral opportunity until January 1, 2017
• Is a non-highly compensated employee (NHCE)
• Had compensation of $80,000 for 2016
• ADP of NHCEs was 8%
Source: IRS Revenue Procedure 2016-51

20
Hypothetical Case Study: Correction
Employer D must make a corrective contribution for the 2016 “missed deferral
opportunity” & the missed matching contribution
• Additional IRS fees & penalties may apply
• Correction amounts add up significantly if eligible errors occur with multiple employees or over multiple years
(Jack’s salary earned during period he was excluded)
(ADP of NHCEs = 8%)
(Missed Deferral)
(50% × Missed Deferral)
(Corrective deferral contribution by employer = Qualified Nonelective Contribution (QNEC))
(50% match on Missed Deferral = $6,400 × .50)
*(Full corrective contribution by Employer D)
*The corrective contribution must be adjusted for earnings through the date of the correction
CALCULATION:*
$80,000
× .08
$ 6,400
× .50
$ 3,200
+ 3,200
$ 6,400

21
3 safe harbor correction methods
No. 50% is a corrective contribution – not
a penalty
3 safe harbor methods require zero or
reduced corrective contribution
• Correction within 3 months of failure
• Correction between 3 months – 2 years of failure
• Correction within 9½ months if automatic enrollment
feature
Is the penalty always 50% of
missed deferrals?
Q
A

22
Employer Z 401(k) plan
• 6 participants in 2016 plan year
• Plan definition of compensation for deferrals &
employer contributions excludes bonuses
• Plan uses unallocated forfeitures to reduce
employer contributions
Incorrect Definition of Compensation
Employer profit sharing &
matching contribution
• 5% of compensation profit sharing
contribution
• 50% matching contribution on deferrals
up to 6% of compensation
Plan Error
• Plan improperly includes bonuses in compensation
• 3 HCEs had base compensation of $120,000 & a $30,000 bonus
• Each HCE deferred 6% of base compensation ($7,200) & bonuses ($1,800)
• Each HCE received a 5% profit sharing allocation on base compensation ($6,000) & bonus ($1,500)
• Each HCE received a 3% match allocation on base compensation ($3,600) & bonus ($900)
Source: IRS 401(k) Plan Fix-It Guide, October 27, 2017

23
Employer Z must take corrective actions for the 2016 incorrect definition of compensation
Incorrect Definition of Compensation
Source: IRS 401(k) Plan Fix-It Guide, October 27, 2017
For each employee, Employer Z should
• Forfeit profit sharing allocations of $1,500, adjusted for earnings
– Reallocate forfeited amounts to use for profit sharing allocation in future year
• Forfeit matching contributions of $900, adjusted for earnings
– Reallocate forfeited amounts to use for matching contribution in future year
• Distribute improperly contributed elective deferral of $1,800, adjusted for earnings, to each
employee
– If earnings are negative, employer must make additional contribution so participants do not suffer financial loss
• If eligible can correct using SCP
• If not eligible must use VCP & correct with IRS filing & appropriate user fee

24
Fiduciary Breaches
DOL Audit “Hot Buttons”
Failing to
• Operate the plan prudently & for the exclusive benefit of participants
• Properly value plan assets or to hold plan assets in trust
• Follow the terms of the plan
• Properly select & monitor service providers
Using plan assets to benefit
• The plan administrator
• The plan sponsor

25
DOL Corrections Program
Delinquent Filer Voluntary Compliance Program
(DFVCP)
• Late or inaccurate Form 5500 filings
Enforcement objective for IRS & DOL
• Form 5500 non-filers
• Key goals
– Modernize reporting
– Improve service provider fee information
– Enhance plan compliance
https://www.dol.gov/agencies/ebsa/employers-and-
advisers/plan-administration-and-compliance/reporting-and-
filing/form-5500
Source: 81 Federal Register 140, “Proposed Revision of Annual Information Returns/Reports,” July 21, 2016
New Form 5500 proposed by DOL, IRS & PBGC

26
Voluntary Fiduciary Correction Program (VFCP)
• Delinquent participant contributions & loan repayments
• Payment of excessive or unnecessary compensation
• Improper handling of participant loans
• Purchase of assets by plans from a “Party in Interest”
• Improper payment of expenses by plan
DOL Corrections Program
https://www.dol.gov/agencies/ebsa/about-ebsa/our-
activities/resource-center/fact-sheets/vfcp

27
Make Timely Deposits
Delinquent participant deposits
• Deferrals
• Loan repayments
Deposit timing rules
• General rule – as soon as possible to segregate
deferrals from general assets
• Small plan safe harbor
– Only available for plans with fewer than 100 plan participants
– 7 business days
Correction resources
• VFCP program
• Online calculator http://askebsa.dol.gov/vfcpcalculator/webcalculator.aspx
Sources: DOL website, Employee Benefits Security Administration, ERISA Enforcement, National Enforcement Priorities, https://www.dol.gov/agencies/ebsa/about-
ebsa/our-activities/enforcement; 29 CFR 2510.3-102, Definition of “plan assets” – participant contributions; VFCP Online Calculator,
http://askebsa.dol.gov/vfcpcalculator/webcalculator.aspx

28
Company A
• More than 100 participants
• Employees paid every other Friday
• Participant deferrals each pay period: $25,000
• Deferrals reasonably can be segregated from
general assets within 5 business days following
each pay day
Delinquent Deposits
Pay period ending March 6, 2016
• Company A should have remitted deferral
contributions by March 13, 2016
(5 business days)
• Date remitted: May 18, 2016
Use the DOL Voluntary Fiduciary Correction Program to correct the late payments

29
Determine corrective contribution amount
• Lost earnings on the principal amount
• Interest on lost earnings
Data for Online Calculator
• Principal Amount: $25,000
• Loss Date: March 13, 2016
• Recovery Date: May 18, 2016
• Final Payment Date: November 4, 2017
Repayment amount: $178.76
• Administration costs (service fees for calculation &
allocation)
Source: Calculations based on VFCP Online Calculator With Instructions, Examples, and Manual Calculations,
https://www.askebsa.dol.gov/VFCPCalculator/WebCalculator.aspx
Delinquent Deposits

30
Increased ERISA Penalties
ERISA VIOLATIONS PRIOR PENALTY ADJUSTED PENALTY
Failure or refusal to file Form 5500 Up to $1,100 per day Up to $2,097 per day
Failure to furnish an automatic
contribution arrangement notice
Up to $1,000 per day Up to $1,659 per day
Failure to furnish information
requested by DOL (e.g., Summary
Plan Description)
Up to $110 per day not to
exceed $1,100 per request
Up to $149 per day not to exceed
$1,496 per request
Failure to furnish a blackout notice
or notice of the right to divest
employer securities
Up to $100 per day Up to $133 per day
Source: 82 Federal Register 11, January 18, 2017

31
Fiduciary Breaches
DOL Audit “Hot Buttons”
Failure to
• Prudently select & monitor plan investments
• Diversify investments to reduce the risk of large losses
• Ensure only necessary & reasonable fees are paid from plan assets

32
Fiduciary Education & Fee Disclosure Review
Plan Fiduciary Risk Management
https://www.dol.gov/sites/default/files/ebsa/a
bout-ebsa/our-activities/resource-
center/publications/understanding-
retirement-plan-fees-and-expenses.pdf
bout-ebsa/our-activities/resource-
center/publications/meeting-your-fiduciary-
responsibilities.pdf
bout-ebsa/our-activities/resource-center/fact-
sheets/final-regulation-service-provider-
disclosures-under-408b2.pdf

33
Qualified Default Investment Alternative (QDIA)
Plans with participant investment direction need default investment
QDIAs provide fiduciary relief for selecting default investments
• Deemed to be a prudent investment
• Relieves fiduciary of liability for performance of default investment
Permitted QDIAs
• Target-date, Custom model target-date, or life-cycle funds
• Managed accounts
• Balanced funds
• Capital preservation product for first 120 days of participation
Plan sponsor responsible for prudent selection & monitoring of QDIA
Source: 29 CFR 2550.404c-5

34
DOL Tip Sheet
Increasingly popular 401(k) plan investment
option
• Often the plan’s default investment
• Qualified Default Investment Alternative (QDIA)
DOL guidance for comparing & selecting TDFs
• Establish process for periodic review
• Understand TDF’s underlying investments & the
fund’s glide path
• Review fees & expenses
• Consider custom or non-proprietary options
• Provide employee communications
• Document the process
Target Date Funds (TDFs)
https://www.dol.gov/sites/default/files/ebsa/about-
ebsa/our-activities/resource-center/fact-
sheets/fsTDF.pdf

35
Investment Policy Statement (IPS)
A written document describing process for selecting & monitoring plan investments
IPS often includes
• Criteria for selecting investments
– Permissible types of investments
– Performance criteria
– Fees & expenses
• Timing of investment reviews
• Standards for adding, changing or replacing investments
Benefits of an IPS
• Provides direction to plan fiduciaries
• Demonstrates fiduciary oversight & prudent process

37
Participants alleged plan fiduciary failure to
• Monitor plan fees
• Benchmark costs
• Follow IPS
Excessive Plan Fees
LESSON 1
• Collect & analyze fee information
• Understand fees being assessed
• Follow IPS
See Tussey v. ABB, Inc., No. 12-2056, 2014 WL 1044831 (8th Cir. Mar. 19, 2014); Lorenz v. Safeway, Inc., No. 4:16-cv-04903 (N.D. Cal. filed 08/25/16)

38
Participants alleged plan fiduciary failure to
• Keep fees reasonable
• Choose appropriate share class
• Follow IPS
• Conduct a competitive bidding process
Excessive Plan Fees
LESSON 2
• Develop written procedures for analyzing fees
• Benchmark fees
• Monitor fees ongoing
See Tibble v. Edison International, C.D. Cal., No. CV 07-5359 SVW-AGRx, August 16, 2017; Kruger v. Novant Health, Inc., 1:14-cv-208 (M.D.N.C. filed 3/12/14); Vellali, et al. v. Yale University, et
al., 3:16-cv-01345 (D. Conn. filed 8/9/16); Kelly, et al., v. Johns Hopkins University, No. 1:16-cv-02835 (D. Md., filed 8/11/16); Sweda v. Unvi. of Penn., No. 2:16-cv-04329 (E.D. Pa., filed
8/9/16)

40
Consider a Committee Approach to Plan
Management
Committee Selected Questions to Consider
Investment
Selection and
Monitoring
 How sophisticated are plan participants in terms of investment knowledge?
 Do asset classes offered allow participants to diversify appropriately?
 What are the criteria for selecting and monitoring investment options?
 Do investment options need to be added, removed and/or replaced?
Administration and
Reporting
 What disclosures and notices are required to be distributed and at what frequency?
 What regulatory forms need to be filed and by what date?
 Is the plan being administered in compliance with the plan document?
 Are transactions—including contributions—processed on time and accurately?
Service Provider
Selection and
Monitoring
 What are the needs of the plan and participants?
 Do participants make optimal use of the services offered?
 How—and how much– is the service provider compensated?
 Do any of the service providers have any potential or actual conflicts of interest?
 Is the total amount of service provider compensation received reasonable compared to an appropriate
benchmark and value of services received?
Plan Design and
Management
 What actions should a participant take in an effort to achieve an adequately funded retirement?
 What plan design features (such as auto-enroll, auto-increase and QDIAs) can help participants
achieve an adequately funded retirement?
 What behavioral finance techniques should be considered to help participants optimize their
retirement plan success?

41
• Develop written operational policies and procedures
• Maintain written records of important activities and decisions
• Maintain your plan’s records
• Investment Policy
• Education Communication Strategy
Establish and Document Prudent Practices and
Policies

42
• Provides a set of voluntary guidelines to transfer the potential liability associated with
investment decision making responsibilities to employees who participate in a 401(k)
plan
• Plan sponsors choosing to comply with ERISA Section 404(c) must meet these key
requirements:
• Provide participants the opportunity to choose from a “broad range” of investment options
• Opportunity
• Choice
• Diversification
• Provide opportunity for participants to “exercise control” over their accounts
• Opportunity for participants to transfer among their investment options at least quarterly
• Additionally, sponsors must provide sufficient information to help participants make
educated decisions about their investment options
ERISA Section 404(c) Protection

44
3. Have you amended your plan document for each plan design change you implemented (e.g.,
automatic enrollment, designated Roth contributions)?
Yes

No

1. Do you have a signed copy of the original plan document & each adoption agreement? Yes

No

2. Have you signed each IRS-mandated amendment & retained a copy?* Yes

No

6. Do you have a copy of the Summary Plan Description (SPD) & amendments to the SPD? Yes

No

4. Do you have a copy of the IRS approval letter for your plan (e.g., opinion letter, determination letter)? Yes

No

5. Have you kept written minutes or records of each board resolution approving the original plan & each
amendment?
Yes

No

Is your plan document up-to-date?
Plan Document Checklist:
* Your plan document provider or legal adviser is the best resource for a list of required amendments.

45
Are the plan’s operations based on the terms of the plan document?
Operations Checklist:
1. Is the plan’s definition of compensation for all deferrals & allocations used correctly? Yes

No

8. Were hardship distributions made properly? Yes

No

2. Were employer matching contributions made to all appropriate employees under the terms of the
plan?
Yes

No

3. Has the plan satisfied the 401(k) nondiscrimination tests (ADP & ACP)? Yes

No

4. Were all eligible employees identified & given the opportunity to make an elective deferral election? Yes

No

5. Are elective deferrals limited to the amounts under IRC §402(g) for the calendar year? Yes

No

6. Have you deposited employee elective deferrals in a timely manner? Yes

No

7. Do participant loans conform to the requirements of the plan document & IRC §72(p)? Yes

No


46
Prevent plan operation errors
Help identify errors more quickly
Reduce the scope/duration of an examination
Importance of Internal Controls
SAMPLE INTERNAL CONTROL PROCEDURES
Compare deferral election forms with amounts deducted from employees’ wages
Verify types of compensation used for allocations, deferrals & testing
Check that service providers received accurate compensation records
Verify years of service are accurately determined for eligibility & vesting
Verify marital status & spousal consent for plan distributions
Ensure participants received required minimum distributions
Verify validity of rollover contributions accepted

47
https://www.irs.gov/government-entities/tax-exempt-and-government-
entities-issue-snapshots
Sample audit tips for plan operations
For example: hardship distributions
• Examine forms & any written statements
provided by the employee for proper
signatures
• Make sure distribution is limited to maximum
amount related to source of funds
• Examine records used to establish whether a
hardship exists & amount of hardship
• Make sure distribution is properly reported on
Form 1099-R
IRS Issue Snapshots

48
Are you prudently selecting & monitoring plan service providers?
Service Provider Checklist:
*Applies when reviewing existing service providers
1. Are the services necessary for the administration of the plan? Yes

No

7. Do you have any plan participant comments or complaints regarding the services?* Yes

No

2. Are the fees reasonable for the services provided? Yes

No

3. Have you documented the process you used to select (or review) your service providers & the reasons
you selected each particular provider?
Yes

No

4. Have you compared the service provider’s performance & fee schedule to other providers (e.g., RFP)? Yes

No

5. Is the service provider required to be licensed? If so, is the license current? Yes

No

6. Has your service provider delivered the services outlined in your service agreement?* Yes

No

See DOL’s Tips for Selecting and Monitoring Service Providers for Your Employee Benefit Plan
https://www.dol.gov/sites/default/files/ebsa/about-ebsa/our-activities/resource-center/fact-sheets/fs052505.pdf
*Applies when reviewing existing service providers

49
Service Provider Checklist
ERISA 408(b)(2) Service Provider Disclosure
Rules
* Applies when reviewing existing service providers.
1 Are the services necessary for the administration of the plan? Yes No
2 Are the fees reasonable for the service provided? Yes No
3 Have you documented the process you used to select (or review) your service
providers and the reasons you selected each particular provider?
Yes No
4 Have you compared the service provider’s performance and fee schedule to
other providers? Benchmarking your plan is a good way to obtain comparative
information.
Yes No
5 Is the service provider required to be licensed? If so, is the license current? Yes No
6 Has your service provider delivered the services described in your service
agreement?*
Yes No
7 Do you have any plan participant comments or complaints regarding the
services?*
Yes No

50
Top 10 Fiduciary Mistakes
Failure to:
1. Establish written policies and procedures
2. Follow policies and procedures
3. Deal with bad investment options
4. Pay attention to fees
5. Administer correctly, monitor periodically
6. Identify conflicts of interest
7. Differentiate between corporate and plan fiduciary roles
8. Appropriately manage company stock
9. Give employees the help they need
10. Take action

52
Support Network
FINANCIAL ADVISOR
• Helps you understand your fiduciary responsibilities
• Regulatory updates
• Self-audit tools
• Gateway to compliance resources
• Investment information
• Resource for industry benchmarks
• Service provider selection & monitoring support
THIRD PARTY ADMINISTRATORS (TPAs) OR
BUNDLED SERVICE PROVIDERS
• Ongoing compliance & operational support
• Proactive monitoring of changes in the law & regulations
• Corrections support

53
Support Network
OTHER SUPPORT SERVICES
• Accounting & audit services
• Tax & legal services
OppenheimerFunds PLAN SPONSOR FIDUCIARY
RESOURCES
• Plan sponsor fiduciary support & educational programs
• Articles, guides & tools

54
Plan Sponsor Next Steps
 Design a compliance strategy
• Access your financial advisor’s expertise to develop a plan
• Identify your other sources of compliance support
– TPA or bundled service provider
– OppenheimerFunds
 Assign internal responsibility
 Set a timetable
• Initial review
• Periodic check-ups
 Document your compliance

55
IRS & DOL engage in both compliance guidance & enforcement activities
Proactive self-audits are essential to ensure compliance
Building a support network is key to ongoing compliance
Summary

56
ERISA is a highly complex area of law. The information contained in this material is strictly educational in
nature and is not intended as legal advice. Clients are strongly encouraged to obtain legal advice from a
qualified expert.
Shares of Oppenheimer funds are not deposits or obligations of any bank, are not guaranteed by any bank, are not insured by the FDIC
or any other agency, and involve investment risks. including the possible loss of the principal amount invested.
This material is provided for general and educational purposes only, is not intended to provide legal or tax advice, and is not
for use to avoid penalties that may be imposed under U.S. federal tax laws. OppenheimerFunds is not undertaking to provide
impartial investment advice or to provide advice in a fiduciary capacity. Contact your attorney or other advisor regarding your
specific legal, investment or tax situation.
Before investing in any of the Oppenheimer funds, investors should carefully
consider a fund’s investment objectives, risks, charges and expenses. Fund
prospectuses and summary prospectuses contain this and other information
about the funds, and may be obtained by asking your financial advisor,
visiting oppenheimerfunds.com or calling 1.800.255.2755. Read prospectuses
and summary prospectuses carefully before investing.
Oppenheimer funds are distributed by OppenheimerFunds Distributor, Inc.
225 Liberty Street, New York, NY 10281-1008
© 2017 OppenheimerFunds Distributor, Inc. All rights reserved.
RPL0000.039.1217 December 1, 2017
Disclosures

Operating in compliance. understanding irs and dol audit hot button issues and how to address them 9-20-18 ce

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