Retirement Advisor Council Submits Comments to the Department of Labor on Information Collection Initiative Regarding 408(b)(2) Disclosure Guide Regulation

The Retirement Advisor Council submitted comments on an information collection initiative by the Department of Labor (DOL) to provide Input into a regulation mandating a 408(b)(2) disclosure guide. In its comments to the DOL, the Council advocates for an expansion of the initiative including one-on-one interviews with Professional Retirement Plan Advisors who are the ultimate guides on which sponsors rely to examine disclosures.

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Alan Spierer, Chairperson of the NAPA Relationship Committee of the Retirement Advisor Council

We are pleased the Employee Benefits Security Administration plans to solicit input from end users regarding 408(b)(2) disclosures and the benefits of a guide to help plan fiduciaries understand disclosures.

East Granby, CT (PRWEB) May 12, 2014

The Retirement Advisor Council submitted comments on an information collection initiative by the Department of Labor (DOL) to provide Input into a regulation mandating a 408(b)(2) disclosure guide. In its comments to the DOL, the Council advocates for an expansion of the initiative including one-on-one interviews with Professional Retirement Plan Advisors who are the ultimate guides on which sponsors rely to examine disclosures, to provide the necessary explanations, to explain how facts and circumstances of their plan impacts services and cost, and to answer baseline and technical questions. The Department initially proposed to limit its observation to fiduciaries of plans with fewer than 100 participants.

The project expansion is not the only suggestion of the Council. Comments address the scope of research, the focus group methodology, the discussion guide the DOL intends to use, analysis and reporting. The Council attached to its comments an edited version of the DOL’s draft discussion guide. Suggested edits concern the balance of questions between the two stated objectives of the information collection, the need for exercises to collect behavioral data in addition to attitudes and opinions, use of more neutral language, removal of the term “hidden fees”, and the addition of questions that reflect market realities such as plan sponsors’ reliance on their Advisor for a range of services and the impact of factors such as employee demographics, sector of activities, and plan design on operating cost. Comments also address the importance of service and fee benchmarking. View the comments at http://www.retirementadvisor.us/commentletters.html .

“We are pleased the Employee Benefits Security Administration plans to solicit input from end users regarding 408(b)(2) disclosures and the benefits of a guide to help plan fiduciaries understand disclosures. The Agency’s efforts to interview final users and their Advisors will be rewarded with rich information and lead to regulations grounded in reality.” said Alan Spierer, chair of the NAPA Relationship Committee of the Retirement Advisor Council. .

The Retirement Advisor Council is a national organization that advocates for successful qualified plan and participant retirement outcomes through the collaborative efforts of experienced, qualified retirement plan advisors, investment managers and defined contribution plan service providers. To advance its mission, the Council undertakes initiatives in the areas of research, public relations and promotion, general public education, regulatory positions and practice management. The Council accomplishes this mission by:
● Identifying duties, responsibilities, and attributes of the Professional Retirement Plan Advisor
● Sharing professional standards with plan sponsors who are responsible for the success of their plans
● Providing collective thought capital to decision makers, product providers, legislators and the public
● Giving voice to the retirement plan advisor community
● Offering tools to evaluate advisors to ensure the quality of services provided.


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