ERISA 404(a) outlines new requirements for disclosing fees to plan participants. These requirements are effective July 1, 2012. Participant investment statements will be changing over the course of the year in order to comply with the new rules.
In addition to new participant fee disclosures, there are new requirements for fee disclosures to plan sponsors. ERISA 408(b)(2) provides guidelines for service providers/advisors to report plan fees to their clients. While we have always detailed fees within our engagement letters, we will be updating all engagement letters to include the new required disclosure language. Look for these new engagements in your mailbox during the fourth quarter of 2011. The new engagements will apply to all services performed on or after July 1, 2012.
An ERPA is a new classification of individual admitted to represent taxpayers before the Internal Revenue Service on a wide variety of retirement plan matters. The ability to practice before the IRS is governed by Circular 230, which requires professional and ethical standards. Enrolled Retirement Plan Agents (ERPAs) are held accountable for their actions, and as such, will provide added assurances to employers when hiring third party administrators or benefits consultants. To become an ERPA, an applicant must demonstrate competency in retirement plan matters through a special enrollment examination, remain current with continuing education requirements, and follow the same standards as all retirement plan professionals. Heartland is pleased to announce that currently four of our staff members have attained the ERPA designation.