The report, A Look at the New Department of Labor Disclosure and Reporting Rules and Their Impact on Plan Fiduciaries, provides an overview of Rule 404(a)(5), what plan fiduciaries should be aware of when evaluating the information contained in the disclosures and potential consequences when plan fiduciaries make disclosures this spring.
The report also provides insight into the temporary rules for electronic disclosure, including safe harbor methods of disclosing electronically. These delivery rules include items that can accompany the quarterly benefits statement participants already receive and that pertain to the voluntary provision of e-mail addresses by participants, the additional material that must be contained in the initial notice when it is being delivered electronically, special provisions for an annual notice and how to confirm that the e-delivery was successful.
“Many participants believe their 401(k) plans are free—until now,” said Timothy Slavin, senior vice president, defined contribution, Broadridge. “We believe concise communication developed in concert with our clients and delivered in the most automated way can improve overall participant understanding of fees associated with their plans. After seeing the fees associated with their account, we expect there to be a flood of questions.”
Slavin added, “Not only do preparations need to be made to comply with the regulation, but third party administrators (TPAs), fund companies and advisers need to consider a comprehensive communication plan after the regulation takes effect.”
A copy of Broadridge’s newly released report on Rule 404(a)(5), an earlier report on Rule 408(b)(2) and an audio replay of a webinar series related to these topics can be accessed via Broadridge’s Fee Disclosure Resource Center located at http://www.broadridge.com/DOLfeedisclosure.