Please feel free to launch a video review of this month’s topic or continue to read on below.

As you’ve probably heard already, the DOL’s final rule on the fiduciary-level and participant-level fee disclosures pushed the deadlines even further than what they proposed last month.

Remember that the fiduciary-level disclosures, which are the breakdown of fees charged by your service providers to you and your plan, were originally required to be provided to you by July 16th (last week), then the DOL proposed to push the deadline to January 1st, 2012, and now they are due to you by April 1st, 2012.  Ironic that it happens to be April Fool’s Day.

The DOL has been mindful that you need a breakdown of the fees before being required to provide that information to your participants so for calendar year plans your new deadlines are:

May 31st, 2012 for the initial disclosures with a narrative explanation of the fees that may be deducted from an employee’s account and
August 14th, 2012 for the quarterly notice which reflects the actual expenses drawn from their accounts.
You will continue to hear more about this as those dates draw closer.

Also, last month I had the opportunity to participate on a panel at the PLANSPONSOR national conference in Chicago.  The panel discussed the issues plans with less than $10 MM typically struggle with and some ideas on how to handle them.

The biggest issue discussed was brokers that advise plans without acknowledging fiduciary status but you already know to avoid that situation.  Another issue discussed was plan amendments.  There have been several over the last few years and they seem to keep rolling in.  You’ve probably had an amendment regarding the suspension of the RMD requirement in 2009 recently roll across your desk.  The bad news is that you have to stay on top of those.

One tip I recommended is the IRS 401(k) Fix-It Guide  found on their website.  It lists eleven common mistakes the IRS finds in their audits, how to fix them, and how to avoid them.  Not adopting plan amendments in a timely manner is one of the common mistakes listed.

Click here to listen to the audio from PSNC:  “Small Plans, Big Challenges”.

Well, that’s all for this month.  I’ll be seeing most of you within the next few weeks and we’ll keep working together on helping you fulfill your fiduciary duties and helping your employees retire successfully.

Best Regards,


Michele L. Suriano TGPC, QPFC, AIF President