Heather Abrigo and I have begun writing articles for third party administrators, TPAs. This first article is about issues arising from a TPA’s own plan, where it is, by definition, a fiduciary. If you are interested in receiving future TPA articles, email [email protected].
At first blush, it seems like 2012 is the year of plan disclosures and participant disclosures. The 408(b)(2) regulation is effective July 1, 2012, and the 404a-5 regulation follows two months later. However, there is more DOL activity than initially meets the eye.
This is another in a series of articles on interesting issues presented under the 408(b)(2) regulation and its disclosure requirements. It has become fairly common for plans to have expense recapture accounts (which are also known as ERISA budget accounts, PERAs—plan expense recapture or reimbursement accounts, and by a variety
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