Often when I first talk with plan sponsors for smaller plans, it is common for them to mention up front that they are very happy with their plan. I have no problem with that. It simply means they do not want to be solicited and that they happen to be loyal to their current providers. I get it! I don’t like to be solicited either and I have loyalties with firms and individuals that have been earned over many years.
But here’s the real problem. If you are a plan sponsor with less than $2 million in assets and fewer than 50 employees, the odds are quite high that your plan may have problems. Many of these issues for small plans are clearly recognizable thru a simple review of Form 5500, if you happen to know where to look. As a professional who regularly reviews hundreds of these forms each month, it is clear to me that small plans have far more problems than larger plans.
This clearly defies common sense or accepted wisdom. After all, lawsuits against plan sponsors typically involve larger, more visible organizations such as Citigroup, Boeing or Yale University. Many sponsors of small plans place a very low probability on the prospects of being sued, so they think they have fewer issues.
“For small plan sponsors, the threat of class action litigation is the least of your problems.“
For a you as a small plan sponsor, the threat of class action litigation is the least of your problems! In practice, it is far more probable that your smaller plan will be subjected to audits conducted by the DOL and Internal Revenue Service based on compliance and fiduciary issues. Many of these are errors of omission. The poison may be different, but the pain is the same.
I once heard a famous cardiologist make the statement: “The first time most people will discover that they have heart disease is just before their head hits the pavement.” Indeed, the first time many small plan sponsors discover that their plan may have serious issues is when they are notified that the DOL has selected them for audit.
The reasons for plan audits can range from certain answers to questions in Form 5500 to possible participant complaints. Increasingly, plan sponsors are selected randomly as the DOL has staffed up to function as a revenue generating agency of the government. Regardless of the reason, audits of all plan sizes result in a loss of productivity for the organization and fines and penalties being assessed in over 80% of all cases.
Most of the issues that surface with the Department of Labor are compliance related, including testing and allocation errors, late transmittals, insufficient fidelity bond coverage, lack of adequate records, applying incorrect compensation formulas, a history of corrective distributions, late filing of Form 5500 and, of course, excessive administrative fees. The corresponding effort to correct these errors, in addition to fines, penalties and possible disqualification, present a greater challenge for small plan sponsors for a number of reasons.
Feelings Will Fool You!
When my youngest son was 11 years old, he spent the summer in a junior golf program sponsored by a local municipal course. He was fortunate to win several age group tournaments and was interested in improving his game. He was then shooting in the mid-80’s, but I knew that if he wanted to improve his skills, he needed professional instruction. We were referred to a local golf pro, Johnny Falsetto, and he and Chris started working together for one hour a week.
One of Johnny’s favorite sayings in teaching his students was the phrase, “Feelings will fool you.” During his first lesson, Johnny did nothing but observe Chris hit balls for most of the hour. After each shot, he would simply say, “Hit another one”. After 50 minutes of this, I was seriously beginning to question whether this guy actually knew anything teaching golf!
At the end of the lesson, Johnny looked up and said, “Chris, to be honest, you have more natural talent than most kids that I have seen at your age. You’re already a good player, but if you want to be a great player, there’s a couple of things that we’re going to have to change”. Then he slowly delivered the challenge, “Chris, get prepared to be really uncomfortable for a while. Feelings will fool you!” After working with Johnny for about a year, Chris was routinely shooting in the low 70’s.
A Golf Lesson for Small Plan Sponsors
I think that this message delivered in this golf lesson applies to plan sponsors of smaller organizations. “Feeling good” about your plan providers without routinely reviewing their performance is not an option under ERISA. Complacency is the cause of many, if not most, of the problems that occur in small plans. In practice, they may delegate some of this due diligence to an experienced advisor. But at the end of the day they know they are personally accountable when things go wrong.
Here are some of the reasons why I think smaller plans have more problems than larger plans.
Smaller plans have less experienced human resource staff.
Larger organizations usually have the resources which allow them greater oversight of their retirement plan. They have the budget to hire human resource officers and employee benefit specialists who are tasked with the responsibility of overseeing the administration of their retirement plan. These professionals have a greater understanding of plan administration and therefore monitor providers more closely than small firms. As a result, they are able to address and correct many administrative and compliance issues before they become real problems.
In truth, plan sponsors have no other choice but to rely on their providers because they don’t know what questions to ask.”
In contrast, the administration and oversight of smaller plans is typically performed by office managers, managing partners or company owners. They are far more likely to rely on plan providers and simply trust that they are not making mistakes. In truth, plan sponsors have no other choice but to rely on their providers because they don’t know what questions to ask.
Going it alone, without the assistance of an experienced plan advisor, is a usually a recipe for disaster.
Larger Plans Are Subject to Audit Checks
Retirement plans with more than 100 participants are required to procure an independent audit from a CPA firm. They are expensive and time consuming but must be submitted along with their Form 5500. The audit’s primary purpose is to verify the financial status of the plan. However, in actual practice, it acts as a crucial check and balance that providers are correctly doing their job. They often reveal hidden plan costs and prohibited transactions that, if uncorrected, could result in penalties, litigation or possible plan disqualification. Smaller plans have a reduced chance of these issues being discovered.
Smaller plans have limited choices for TPA providers.
Because of industry pricing, smaller plans often go with bundled providers who provide TPA services through revenue sharing arrangements. These providers are paid through hidden fees buried in higher expense ratios for plan investments or expensive wrap fees. In the attempt to make the plan costs more affordable for plan sponsors, they have simply shifted higher fees on the backs of participants. Many of these small plan sponsors insist that they pay nothing for administration when in fact their participants pay a much higher percentage for fewer services than larger plans.
Hiring a good TPA is one of the most important decisions that you make as a plan sponsor. You are ultimately responsible for mistakes, errors and fraud which may occur due to their negligence or inexperience. The good news in the small plan market today is that there are many outstanding options for TPA services which are both cost efficient and accurate.
Smaller plans are more likely to experience administrative problems.
Plans designed by payroll providers, insurance companies and bundled mutual fund companies are often sold as a product. Design errors are frequent and TPA’s for these plans are often overburdened, have high turnover and lack a single point of contact. There is nothing more frustrating for a plan sponsor than having to speak to someone new each time there is a question or a problem. Often, there is really no one to consult for accurate fiduciary guidance.
I recently discovered a local TPA for a prospective client was 6 months late in filing their Form 5500. The TPA’s excuse was the unexpected death of a spouse for the employee assigned to the task. Although a tragic circumstance for the employee, it did not excuse the TPA of the duty to their client.
A late filing for Form 5500 is a huge red flag and this client now faces a higher probability of a future audit as a result. The fines for this error are also quite punitive- up to $2,140 per day. Additional IRS penalties for late filing are $25 per day up to a maximum of $15,000 per occurrence.
Late filing is an unforced error and a “rookie mistake” for any TPA firm. Short of the client itself being uncooperative or unable to supply the needed census data, it is simply inexcuseable.
My recommendation to this client? Regardless of your personal loyalties or friendship, you have no choice but to hire a new provider.
Larger plan providers, on the other hand, generally are more independent, have more checks and balances in place and have a single point of contact which enable them to proactively avoid most common errors. Because they generally have more training and less turnover, these providers are better able to spot plan errors and self-monitor each other. Many TPA’s provide access to ERISA attorneys to further assist with correcting issues that may arise from time to time.
Small plans are more likely to hire the wrong advisor.
What I see frequently with small plans is an advisor who is a family member or acts as the personal wealth manager or financial planner for one or more of the firm’s owners or managing partners. This is a dead giveaway to me that the plan may have more serious issues.
Their qualifications often do not match up with the job requirements of a true retirement plan advisor.
Mariners pitching coach
As a way of illustrating, suppose the Seattle Mariners were to hire a successful pitching coach. Without question, they will be looking for a candidate who knows a lot about pitching. This candidate must be able to communicate clearly and can spot and correct poor mechanics before they become ingrained habits and result in poor performance. Most good candidates will be former pitchers that had good careers in the major leagues.
Now suppose the Mariners needed to fill an open position for a batting coach. Their process would focus on candidates experienced with proper swing fundamentals and similar ability to observe and correct swing flaws. Usually, the best candidates have put up consistent hitting statistics as a player.
Having hired these coaches, it would be highly unusual for the Mariners to then rotate their pitching instructors to work with hitters or conversely ask the batting coaches to work with the pitching staff. Their roles within the organization are both unique and specialized.
So too the distinction between individual wealth managers and institutional retirement plan advisors. The job descriptions for these advisors are radically different. Baseball is highly specialized. So is the investment world. An arbitrage manager and a manager for a small cap value fund both purchase stocks, but for very different reasons strategies and holding periods.
Institutional investment advisors create and monitor plan investment menus and assist plan sponsors with fiduciary guidance and participant education. Wealth managers and financial planners assist individuals to achieve their own unique financial goals. They both understand financial instruments, but their job descriptions are unique and specialized.
Watch out for advisors who have conflicts of interest.
“Try this – I just bought a hundred shares!”
Hiring advisors who are directly or indirectly affiliated with other providers can present other problems. Some TPA firms like to package their plans with advisors who are apathetic to their higher fees.
These arrangements are highly unethical yet are more common than you might assume in the small plan world.
Psst… Here are a few of the red flags that will help you identify these “advisors”:
A pre-set investment lineup with proprietary funds and revenue sharing arrangements that benefit one or more providers or certain preferred vendors. I know a local TPA that has a majority of its clients using a high priced insurance company as its exclusive recordkeeper because of revenue sharing arrangements with that company.
Failure to provide written evaluations of plan investments. At best, their actual investment advice is re-active rather than pro-active, since replacing current investments may result in reducing the advisor’s total compensation.
No investment policy statement (IPS). Although not legally required, an IPS is part of a sound fiduciary process and serves as the basis for all future investment decisions. A sound IPS would in most cases shine a light on unreasonable fees or proprietary investments which benefit providers.
Failure to actually follow the IPS. A plan which has agreed on an IPS yet does not consistently follow the process is opening itself up for future liabilities. It would almost be better had they not had an IPS in the first place. If you have one, you better follow it.
The advisor does not provide on-going education regarding plan investments to the participants as required in Section 404 (c). Simply handing out investment materials or informational brochures does not meet this standard.
In contrast, larger plans more frequently hire advisors who are both fiduciaries and specialize in company sponsored retirement plans. Smaller plans should do the same.
An independent advisor experienced in ERISA can help you in your obligation to review the performance of your other providers. He knows the right questions to ask and can keep you out of trouble.
Small plan sponsors must be diligent in their oversight of providers.
This article has pointed out a number of reasons that smaller plans tend to run into more problems than those of larger plans. But it doesn’t have to be that way.Assembling a team consisting of independent providers is a practice that will pay off in the long run for small plan sponsors.
The next time you say that you are happy with your plan, make sure that you have subjected it to a professional review.
Because feelings will fool you!
Brian C. Rall
President – Strategic Retirement Partners, LLC
March 2, 2020
Strategic Retirement Partners is an independent, boutique investment advisory and consulting firm providing plan design, vendor search, investment selection, fiduciary guidance and participant education for company sponsored retirement plans.
Strategic Retirement Partners, LLC is a registered investment advisor in the State of Washington. The investment advisor may not transact business in states where it is not appropriately registered, excluded or exempted from registration. Any information contained herein or on SRP’s website is provided for educational purposes only and is not intended to make an offer or solicitation for the sale of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated are not guaranteed. SRP does not provide legal or tax advice and clients should consult their attorneys and CPA for any strategy discussed herein or on this website.
Plan Sponsors Need to Understand the Hardship Rules
A 401(k) plan may allow participants who face certain types of financial stress or emergencies to request a distribution from their account balance. Allowing hardship distributions from your 401(k) may in fact be a plan feature that benefits certain participants who are financially distressed yet puts an added burden on plan sponsors to understand and properly implement IRS regulations. Failure to do so may subject them to severe consequences, including fines, penalties and plan disqualification.
In November of 2018, the IRS proposed changes to hardship distributions, including how and under what circumstances they could be received by participants. Beginning in January of 2019, employers were allowed to implement certain of these changes prior to them becoming finalized by the IRS.
Since I am frequently asked questions regarding hardship distributions by plan sponsors, we thought it might be helpful to review some of the most FAQ’s regarding these often misunderstood guidelines.
Are all 401(k) plans required to permit hardship distributions?
No. The decision to allow hardship distributions is an option available either when the plan is originally established or as an amendment to an existing plan. Keep in mind that individual plan demographics may work against allowing this feature if a higher percentage of participants may find themselves qualifying for these distributions.
What are the qualifications for a participant to request hardship distributions?
A 401(k) participant must satisfy two criteria in order to qualify for a hardship distribution:
He or she must have an “immediate and heavy financial need”.
The distribution should be “limited to an amount necessary to satisfy that need”.
What is the IRS definition of hardship for a 401(k) plan?
In addition to the employee’s immediate and heavy financial need, the definition includes those of an employee’s spouse, dependents and beneficiaries. Employers are allowed determine certain qualifying events of hardship under two options:
Use the IRS Safe Harbor definition.
Use a custom definition.
In the great majority of cases, plan sponsors elect to use the Safe Harbor option which lays out 6 events which qualify as a participant hardship:
Medical care for the employee, the employee’s spouse, dependent or beneficiary.
Direct costs related to the purchase of an employee’s personal residence, not including the mortgage.
Tuition, fees and room and board expenses for the next 12 months of post secondary education for an employee, an employee’s spouse, dependent or beneficiary.
Payment necessary to prevent eviction or foreclosure on a participant’s primary residence.
Funeral expenses for the employee, employee’s spouse, dependent or beneficiary.
Certain expenses to repair damage to an employee’s permanent residence.
How do we calculate the amount necessary to satisfy the immediate financial need?
The IRS regulations make it clear that the distribution may factor in the impact of taxes and penalties that may result from qualified hardship distributions. In addition, employers should make the determination that the employee could not reasonably obtain liquid funds from any other source.
In addition, employers are allowed rely on the employee’s written statement that the need cannot be relieved from other resources, including insurance or other reimbursements, liquidation of the employee’s assets, the employee’s wages after termination of all elective deferrals and plan or “reasonable” commercial loans.
What documentation should employers obtain as part of the hardship distribution application?
Employers are allowed to choose one of two options in regard to the proper documentation of all plan hardship distributions:
Traditional Substantiation:
Under this method, employers obtain the actual source documentsthat substantiate the need. This is the only method that is acceptable for non-safe harbor hardship qualification.
Summary Substantiation:
Employers rely on a written, participant-provided summaryof the hardship, provided that the summary includes certain, required information.
In every case, plan sponsors should retain these documents according to the document retention rules established under ERISA.
What are the financial consequences of hardship distributions on participants?
Hardship distributions can have severe and significant financial impacts upon participants in that they are included in gross income unless they consist of designated Roth contributions. Participants who have not yet attained the age of 59 ½ are subject to additional penalties of 10%. Finally, because hardship distributions cannot be repaid to the plan or rolled into another qualified plan, the compounding impact of future lost income due to these withdrawals can be significant.
What are the IRS proposed rule changes to hardship distribution regulations?
The IRS implemented a number of significant changes to the current hardship regulations and issued a proposal draft in November of 2018 outlining the changes. Plan sponsors were allowed to implement these changes on January 1, 2019 or alternatively, they may choose to wait until the changes are finalized.
Removal of the six month suspension rule following a participant distribution. Under current rules, participants are prevented from making contributions to the plan for a 6 month period. Employers have the option in 2019 to remove this suspension and are mandated to do so beginning January 1, 2020.
Current regulations limit the source of contributions eligible for distributions, excluding QNEC’s, QMAC’s, safe harbor contributions and earnings on elective deferrals. The new proposal lifts these restrictions. Implementation is optional, not mandatory.
Under current standards, participants are required to take a loan prior to requesting a distribution. The proposal eliminates this provision.
Employers currently must consider all relevant facts and seek relevant documentation. The proposal allows them to rely on written representations from participants that he/she has sufficient liquid assets to satisfy the need, unless the employer has knowledge to the contrary.
An additional qualifying event – expenses resulting from federally declared disasters– has been added to the safe harbor list of qualifying events.
What is the deadline for making plan changes based on the current proposed changes?
Employers can elect to rely on the proposed changes beginning this year prior to a formal plan amendment. However, the Treasury Department and the IRS expect that, if these regulations are finalized as proposed, plan sponsors will need to amend their plan’s hardship distribution provisions. As of this writing, the guidance is that most amendments will need to be made within the period ending the second year following the year that the rules have been finalized. (See section “Plan Amendments” in IRS Proposed Rule for details.)
In the interim, plan sponsors should consult their providers for guidance on implementation of these new proposed rules.
Concluding Thoughts for Plan Sponsors:
Hardship distribution provisions in 401(k) plans provide a valuable benefit to participants who may be experiencing temporary financial stress due to certain qualifying circumstances and to employers who may lose productivity from these employees. However, they put additional burdens on plan sponsors to properly understand the rules and have a process in place to implement their requirements. Best practices include proper documentation and retention for each request as well as full disclosure of the financial consequences to participants. Your plan providers should be consulted prior to giving specific guidance as they may require specific forms and disclosure documents that apply.
Plan sponsors electing to amend their plans to allow hardship withdrawals must do so during the current plan year and disclose the details of this change to participants by December 1 to have the changes take effect in the next plan year.
Brian C. Rall
President – Strategic Retirement Partners, LLC
Strategic Retirement Partners is an independent, boutique investment advisory and consulting firm providing plan design, vendor search, investment selection, fiduciary guidance and participant education to company sponsored retirement plans.
Strategic Retirement Partners, LLC is a registered investment advisor in the State of Washington. The investment advisor may not transact business in states where it is not appropriately registered, excluded or exempted from registration. Any information contained herein or on SRP’s website is provided for educational purposes only and is not intended to make an offer or solicitation for the sale of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated are not guaranteed. SRP does not provide legal or tax advice and clients should consult their attorneys and CPA for any strategy discussed herein or on this website.
Your Insurance Company’s 401(k) Fees Are Too High!
The Cost of Cell Phones and 401(k) Services in 1985.
I purchased my first cell phone in 1985. It was a Motorola DynaTAC model and it was more or less permanently attached to the center console of my car. “The Brick” was not portable, provided only voice telephone service and cost over $9000 when it was introduced in 1984. Today, a smartphone fits in your pocket, provides an unlimited number of functions and (depending on the model) costs just a few hundred dollars.
If you were a small business or professional organization shopping for a 401(k) provider in 1985, you would have also had few, if any, choices outside of an expensive insurance company to provide recordkeeping, investment options and compliance services. Today it’s a different story for these smaller plans.
The availability of low cost 401(k) recordkeeping, administration and compliance services for smaller plans today is very much a reality. Despite this fact, a shockingly high percentage of these smaller plans are still managed by bundled insurance company providers and are among the most expensive 401(k) options for smaller businesses, including physicians, dentists and attorneys.
Why We Put Up With High Fees.
The question we should all be asking is why insurance company plans so expensive. And more importantly, why do plan sponsors continue to put up with these high costs?
My answer? Insurance plans are expensive because the insurance companies know they can get away with higher fees. And many of these plan sponsors either don’t know or don’t care. They should.
Despite all of the sophisticated and expensive marketing and enrollment materials they provide to plan participants, insurance companies are often the least transparent in regard to plan fees. In many cases, their fees are simply buried in annuity contracts with employers. And when employers decide to change providers, surrender charges can hold them hostage. This makes it nearly impossible for a plan sponsor to meet their fiduciary responsibility regarding reasonable fees.
Are My Plan’s Fees Reasonable?
Plan sponsors have a fiduciary responsibility to ensure that their 401(k) fees are reasonable. In practice, this requires that they calculate the “all-in” fees (service provider fees + investment fees) and compare these fees to 3 or more providers. This benchmarking process should be done on an annual basis.
Your fees don’t have to be the lowest available in order to be reasonable. But they must be justified based on the services received. At my firm, we work with 401(k) providers whose fees are transparent. In practice, lack of fee transparency is the most common red flag that your fees are too high.
What Do Variable Annuities Have to Do With High Plan Costs?
If your retirement plan’s provider is an insurance company, your plan’s investments are likely a variable annuity. Understanding the differences between a variable annuity and a mutual fund is key to unlocking the high fees typically associated with insurance providers.
Variable annuities are essentially mutual funds wrapped in a layer of insurance that renders the investment returns and income from the investment tax-deferred. This makes them an attractive alternative to certain individual investors who may be in higher tax brackets.
When used inside a 401(k) retirement plan, however, this is a distinction without a difference, since all investments returns inside of a 401(k) are already tax deferred. So, do variable annuities have other advantages when used in a 401(k) plan? Not really. But they present a number of disadvantages, including additional fees and onerous trading restrictions.
Wrap Fees, Surrender Charges and Commissions.
A retirement plan funded by variable annuities is structured so that participants do not directly own a mutual fund. Instead, they own “units” of an account that holds mutual funds owned by the insurance company. These units have a variety of wrap fees including investment management fees, surrender charges, mortality and expense risk and administration fees. Variable annuities also include a commission which is paid to the broker who sold them.
These fees can range from .25% up to 1.25% of assets, depending on the size of the plan. They are often estimated as a percentage of assets in 408b-2 fee disclosures, as opposed to stating the actual dollars that are being extracted from participants. Even more frequently, they are buried in dense and often confusing group annuity contracts with the employer. These hidden fees can be destructive to your long term financial health. A plan with total assets of $1 million invested in a group annuity with a 1.00% wrap fee would generate annual hidden compensation of $10,000 to insurance companies and plan advisors yet provide questionable participant benefits. And since these fees are variable based on assets, they are increasing over time.
Surrender Charges: Adding Insult to Injury.
One of the most devastating wrap fee consequences associated with plans funded with variable annuities are serious and onerous trading restrictions. Because annuity contracts are written with an expiration date, an employer who wishes to terminate the contract prior to expiration is subject to surrender charges often as high as 7%. While the industry defends these fees as an offset to the cost of setting up the plan, their true and obvious purpose is to hold plan sponsors hostage. They create a nightmare scenario for plan sponsors who wish to terminate their provider for poor performance or high administrative fees.
Revenue Sharing Arrangements: Hidden Fees
Revenue sharing arrangements are another source of hidden fees for participants. These fees are far from transparent and are often buried within the expense ratios of plan investments. Often identified as 12b-1 and sub-TA fees, these fees are used to indirectly compensate recordkeepers, custodians, TPA’s and advisors for services provided to the plan. Because the true cost of most plan services scale based on the number of plan participants as opposed to the total plan assets, these fees become increasingly expensive as plan assets continue to grow. They are seldom justified.
“I Own A Mutual Fund in My 401(k), Right?”
Variable annuities are often identified in marketing materials and other plan communications by their underlying mutual fund. This can lead some participants to conclude that they are investing directly in a mutual fund when in fact they are investing in variable annuity units subject to additional fees. As a result, plan participants who wish to invest in low-cost mutual funds may not realize that while the underlying fund has low fees, the unit expenses could be considerably higher. That’s not my idea of transparency!
Good News! You’ve Got Options!
Fifteen or twenty years ago, the smallest 401(k) plans had few options outside of variable annuities and bundled insurance providers. Today, the 401(k) landscape has changed. Mutual fund minimums have been reduced and lower cost share classes are available on most competitive recordkeeping platforms. Regulatory reform in recent years has mandated fee disclosure to both plan sponsors and participants. As a result, there has been an acceleration in the number of insurance companies who have sold or exited their 401(k) recordkeeping business in the past 5 years.
What Must I Do Now?
Insurance companies get away with high fees for two reasons: The first reason is that their fees are often intentionally hidden. True, fee disclosure reform has increased transparency somewhat in recent years, but insurance company fee disclosure continues to be among the most confusing and least transparent.
I have found that many, if not most, plan sponsors need help when it comes to properly identifying and benchmarking their 401(k) plan fees. You should ask your advisor for help if he is not already providing you with that service.
You should also understand how your advisor, as well as other 401(k) providers are paid for their services. Revenue sharing arrangements and insurance company wrap fees are often expensive and involve conflicts of interest that should be avoided.
Apathy and indifference among plan sponsors when it concerns high fees, however, is both expensive and inexcusable. Putting up with high 401(k) fees charged by insurance providers when there are far less expensive options available to smaller plans increases your legal liability, reduces participant outcomes and is a serious breach of fiduciary responsibility. Both you and your employees deserve better.
Brian C. Rall
President – Strategic Retirement Partners, LLC
Strategic Retirement Partners is an independent, boutique investment advisory and consulting firm providing plan design, vendor search, investment selection, fiduciary guidance and participant education to company sponsored retirement plans.
Strategic Retirement Partners, LLC is a registered investment advisor in the State of Washington. The investment advisor may not transact business in states where it is not appropriately registered, excluded or exempted from registration. Any information contained herein or on SRP’s website is provided for educational purposes only and is not intended to make an offer or solicitation for the sale of any specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated are not guaranteed. SRP does not provide legal or tax advice and clients should consult their attorneys and CPA for any strategy discussed herein or on this website.
It is highly probable that your company’s 401(k) plan will be subjected to audits conducted by the DOL and the Internal Revenue Service at some point in the future. If you are not 100% certain what documents you will need, download this free copy of our “Fiduciary Audit File Checklist” and be sure!