September 07, 2021 Features Comments From Fred Reish on DOL Rollover Compliance

In “Getting Ready for Expanded Rollover Disclosure Requirements,” shared insights from benefits and executive compensation partner Fred Reish about the Department of Labor’s (DOL) response to FAQ 15 regarding rollovers and potential compliance challenges, including documentation.

The publication noted that the DOL suggests that in cases where the 404(a)(5) document isn’t available, alternative data sources, such as the most recent Form 5500 or “reliable benchmarks on typical fees and expenses for the type and size of the plan at issue” could be used.

However, in Faegre Drinker’s “Inside the Beltway” webinar, Reish pointed out that Form 5500 covers only large plans, typically those with 100-plus participants. Smaller plans file Form 5500-SF, which does not include the plan’s investment information. As a result, compliance for rollovers is likely to become more time-consuming and difficult by year-end.

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