In light of the complexity and comprehensive nature of the participant-level disclosure requirements, Employee Retirement Income Security Act (ERISA) plan sponsors will be required to take steps well in advance of the first disclosures being delivered to participants, and will need to coordinate closely with their external recordkeepers and investment option providers, PricewaterhouseCoopers (PwC) notes in its latest HRS Insight. PwC said investment providers and recordkeepers will need to be prepared for such directives from plan sponsors.
The firm recommends the following actions:
- Become familiar with DoL Model Comparative Chart in order to understand and be prepared to deliver the different components of the information that must be disclosed by plan sponsors;
- Closely monitor the developments surrounding the participant disclosure regulations and make adjustment to any participant communications as necessary;
- Develop tools and resources to help clients deliver the disclosures and address their communication needs;
- Establish and provide for access to the required web-related disclosures;
- Meet with clients to commence discussion on the availability and retrieval of the investment-related and expense information;
- Assist clients with developing a communication program for such information;
- Incorporate the enhanced fee disclosure requirements into existing practices with respect to the disclosure of all fees charged to each individual’s plan account;
- Assess the business risk associated with disclosure requirements and train internal staff on clients’ compliance requirements with respect to such rules; and
- Consider the additional costs that may be incurred to fulfill client requests for information in order to satisfy the applicable disclosure requirements.
Visit http://www.pwc.com/hrs for more information.