June 23, 2014

Fred Reish Quoted in Dow Jones Factiva

Los Angeles partner Fred Reish was quoted in a Dow Jones Factiva article titled, “Engaging Participants.”

The article discusses why it is imperative that advisers  keep up to date with  regulatory guidance memoranda  issued by the DOL. Fee disclosure  documentation under ERISA Section 408(b)(2) is not only relatively new and subject  to revision, but it also can be difficult for plans to decipher.

Fred, who writes  regularly about  fee disclosure  requirements for publications such as PLANSPONSOR, has said that  the requirements can present  a heavy burden on service  providers, in that  they  must  document very  precisely  where they have made disclosures.

"It appears that  the DOL is concerned  that,  by using multiple disclosure documents or lengthy  or complex  documents service providers may have presented  the disclosure  in a manner  that  is difficult for plan sponsors  to understand," Fred wrote  in a blog entry  earlier  this year.  While the DOL wants to help make it easier for sponsors to grasp the disclosure data, it also is incumbent upon advisers to help interpret all such disclosure that is material to their plans.

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