{ "media_type": "text", "post_content": "What is RIA obligation for fee reporting? We provide info on our management fees. TPA/recordkeeper does not provide info on fund fees. Are we as advisors obligated to do so and how often to report?", "post_id": "5a3547340df91800131cb9d8", "reply_count": 6, "vote_count": 1, "bowl_id": "59d8e13f4d57b200118168ef", "bowl_name": "Retirement Plan Advisors", "feed_type": "bowl" }

What is RIA obligation for fee reporting? We provide info on our management fees. TPA/recordkeeper does not provide info on fund fees. Are we as advisors obligated to do so and how often to report?

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Sounds like you should find a new RK/TPA. That is their duty.

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Talk to flexible benefits I'm Ohio or rpg consultants. Great guys, tell them I sent you.

Have the TPA/Recordkeeper read up on Qualified Plan Fee Disclosures – 404(a) and 408(b)2. If they aren’t providing the required disclosure, plan sponsor should fire immediately.

TPA and recordkeeper absolutely provide 408b2 and 404a5 notices for investment and administrative fee disclosures on their system. I guarantee it. OP - do you hold assets away from the recordkeeper? If so, as a covered service provider you will need to disclose what you control.

Blanket statements and “guarantee” statements are wrong. For example: flat fee based, self-directed equity 401(k) for which I have discretion

That was my comment posted above under SFC1 and it was not a general statement, nor wrong. When assets are held on the system of a 401k recordkeeper, the recordkeeper will generate 408b2 and 404a5 notices disclosing investment fees and their administrative fees as a covered service provider - it is their legal requirement. If assets are held away from the recordkeeper, then the recordkeeper would not disclose investment fees since it is not under their purview. That would fall to the custodian of the assets since they should be registered as retirement plan assets. The custodian - RIA or other - must disclose their investment and admin fees as a covered service provider. The only way fund expenses are not being disclosed is if a participant is using the self-directed brokerage option within a turnkey 401k platform wherein the participant has access to a vast universe of investment options. In that case the recordkeeper must only disclose the fees for maintaining the SDBA feature. SDBA is a participant elected option, not a plan level arrangement. OP suggests they manage/hold plan assets, which would require RIA disclosure of fund fees. FA1 - sounds like you charge participants a fee to manage their SDBA inside a 401k plan.

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