Recently the Department of Labor issued new regulations that require Plan Sponsors to distribute a 404(a)(5) Fee Disclosure Notice ("404(a)(5) Notice") to all plan participants.  Trinity assisted you with the completion of this notice requirement by providing you with our portion of the necessary information before the August 30, 2012 deadline. 

 

What was this all about anyway?

 

404(a)(5) Participant Fee Disclosure Requirements FAQ

 

1. What is the purpose of the 404(a)(5) Notice?

 The purpose was to help plan participants understand the fees and expenses associated with their plan.

 

2. When must the 404(a)(5) Notice be distributed?

The initial Annual Notice was to be distributed no later than August 30, 2012 (for calendar year plans). 

 

The initial Quarterly Expense Notice must be distributed no later than November 15, 2012 (for calendar year plans).  All future Quarterly Notices must be distributed within 45 days of the end of the quarter.

 

If there are any changes to the plan's fees during the year, a Plan Change Notice must be distributed to participants 30 days before the change takes place.

 

If there are any changes to the plan's investment funds during the plan year, a Fund Change Notice must be distributed to participants 30 days before the change takes place.

 

3. What are my responsibilities with regards to the 404(a)(5) Notices?

Plan Sponsors are responsible for providing the required information to plan participants in an easy to comprehend format.

 

Plan Sponsors will also need to notify Trinity of any fund changes or changes to fees during the year so that we can prepare the Plan Change or Fund Change Notice(s).

 

4. Who will prepare the 404(a)(5) Notice?

Trinity Pension Consultants will work with your investment provider to prepare your Annual Notice, as well as any requested interim Plan Change or Fund Change Notices before the required deadline.

 

5. What if my plan uses a Brokerage Account?

Trinity Pension Consultants cannot prepare notices for Self- Directed Brokerage Accounts.

 

If you have Self Directed Brokerage Accounts within your plan, you will need to work with your Financial Advisor to prepare the 404(a)(5) Notice.