In particular, ERIC's letter highlights the fact that as most plans operate on a calendar year basis, requiring plan sponsors to distribute participant fee disclosures “off-cycle” with these other year-end disclosures causes undue administrative burden and additional cost.
ERIC asked that the Department interpret the regulation’s definition of “at least annually thereafter” to at least once in any twelve-month period, but no later than 18 months from the last annual disclosure.
The comment letter is available here.
ERIC asked that the Department interpret the regulation’s definition of “at least annually thereafter” to at least once in any twelve-month period, but no later than 18 months from the last annual disclosure.
The comment letter is available here.

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