May 2019 update

Some information and thoughts after attending a pension conference (accountants please be sure to see item #2): Fixing plan defects is somewhat easier.  We’d like to think our plans are perfectly run, and in fact we think they are certainly run better than most, but to be honest, I could probably find something wrong with […]

3(16), 3(21) and 3(38) Fiduciary Services – what are they all about?

Short answer – for our clients, wasting money.  See below for more info. 3(16) services are administrative services performed by someone else on behalf of the Plan Administrator (usually the employer) – essentially, outsourcing administrative duties such as maintaining and interpreting the plan document, providing notices, etc.  We do all of this for our clients, […]

Latest (latest!) on the fiduciary rule

As discussed in an earlier blogpost (and here, and here), the Fifth Circuit Court of Appeals, covering Louisiana, Mississippi, and Texas, determined that the rule is impermissible (by a 2-1 vote on a 3 judge panel).  Several organizations, including AARP, requested standing as defendants but those motions were denied, and the Department of Labor, which […]