Webinar Slides: Understanding Your ERISA Fiduciary Responsibilities

CBIZ & MHM Executive Education Series™ Understanding Your ERISA Fiduciary

Responsibilities Presented by: Hal Hunt, Cindy Dwyer,

Linda Lauer & Lisa Goyer of Husch Blackwell

October 9, 2014

2 #CBIZMHMwebinar Co-presented by

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Before We Get Started…


This webinar is eligible for CPE credit. To receive credit, you will need to answer periodic participation markers throughout the webinar.

External participants will receive their CPE certificate via email immediately following the webinar.

CPE Credit


The information in this Executive Education Series course is a brief summary and may not include all

the details relevant to your situation.

Please contact your service provider to further discuss the impact on your business.

Disclaimer


Today’s Presenters

Linda Lauer, CPA Shareholder 901.685.5575 | [email protected] Linda leads the EBP Audit practice for MHM’s Memphis office. She is the main contact for benefit plan audit engagements and is responsible for overall coordination and efficient utilization of firm resources. Linda has more than 25 years of experience with international and local accounting firms and employee benefit administration for Fortune 500 companies. She frequently conducts seminars and webinars on plan audits as well as plan administration issues and fiduciary responsibilities.

Lisa Goyer Senior Counsel, Husch Blackwell 417.268.4111 | [email protected] Lisa has more than 25 years of in-house and law firm experience advising public and private companies regarding employee benefit program design, legal compliance and fiduciary responsibility. She joined the firm in 2014 after 12 years of serving as Of Counsel at DLA Piper LLP.


Today’s Presenters Hal Hunt, CPA Shareholder 913.234.1012 | [email protected]

Hal leads MHM’s Employee Benefit Plan (EBP) Audit Practice. With over 25 years of diverse experience with EBP accounting, auditing and compliance issues, he is also a member of the firm’s Professional Standards Group as EBP subject matter expert. As the EBP National Practice Leader, Hal is responsible for providing internal training, along with providing technical support to engagement teams, serving as engagement quality reviewer and developing resource tools for our EBP audit professionals. He served on the AICPA’s Employee Benefit Plan Audit Quality Center (EBPAQC) Executive Committee and is currently a member of the EBPAQC ESOP Task Force.

Cindy Dwyer, CPA Shareholder 913.234.1022 | [email protected] Cindy is the President of MHM Retirement Plan Solutions and a Shareholder of Mayer Hoffman McCann P.C. She supervises staff, oversees technical research, and provides quality control services. She has previously served as the national Chairperson of the American Institute of Certified Public Accountants Employee Benefits Technical Resource Panel (TRP) and currently serves as an advisory member of the TRP. Additionally, Cindy has been a recurring speaker at the American Institute of Certified Public Accountants National Conference on Employee Benefit Plans. Cindy is also a committee member and former chair of the Employee Benefits Institute sponsored by UMKC School of Law.


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Today’s Agenda

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Overview and Background Who is a Fiduciary? Fiduciary Risks and Responsibilities Challenges to Meeting Fiduciary Responsibilities Practical Considerations Resources

OVERVIEW AND BACKGROUND


ERISA Fiduciary Responsibilities This webinar covers the scope of ERISA’s protections for

private-sector retirement plans (public-sector plans and plans sponsored by churches are not covered by ERISA). ERISA sets standards of conduct for those who manage an

employee benefit plan and its assets (called fiduciaries). Administering a retirement plan and managing its assets

require certain actions and involve specific responsibilities. Employers often hire outside professionals (sometimes called

third-party service providers) or, if applicable, use an internal administrative committee or human resources department to manage some or all of a plan’s day-to-day operations.

There may be one or a number of other officials with discretion over the plan and they are plan fiduciaries.


Significance of Being a Fiduciary

Act solely in the interest of the plan participants and their beneficiaries, with the exclusive purpose of providing benefits to them

Carry out their duties prudently Follow the plan documents, unless inconsistent with

ERISA Diversify plan investments Pay only reasonable expenses Disclose required plan-related fees and expenses to plan

participants Review service provider performance


The rules regarding fiduciary responsibility are enforced by the Employee Benefits Security Administration (EBSA) and the federal courts

EBSA enforcement results for 2013 fiscal year: Total monetary results: $1.69 billion Civil investigations:

3,677 civil closed 190 civil investigations referred for litigation

Criminal investigations: 320 closed 70 with guilty pleas or convictions 88 individuals indicted

Complaints 236,551 received 775 investigations opened $281.3 million recovered

EBSA Enforcement of ERISA’s Rules


Fee Disclosures 408(b)(2) Vendor to Sponsor – due July 1, 2012 404(a)(5) – Participant Fee Disclosure – due no later than 60 days

after July 1, 2012 for plan years beginning November 1, 2011 through July 1, 2012

Lifetime Income DOL is expected to issue proposed regulations in upcoming year for

plan qualification rules utilizing an annuity option and for showing annuity equivalents on participant statements

Target Date Funds DOL to provide a Fiduciary checklist Possible enhanced participant disclosures

Fiduciary Investment Advice DOL to propose regulations regarding broadening the circumstances

in which a person/entity can provide investment advice to a plan participant

Legislative Updates 2012 to 2014


12b-1 Reform Possible SEC final rules that may change the current rules regarding

the use of fund assets to pay for expenses associated with the distribution of fund shares

Reduced Contribution Limits Possibility that legislation for tax reform and budge deficit may have an

impact on reduction of contribution limits Anti-leakage Legislation that would extend the rollover period for plan loans,

possibly allow participants to continue to contribute after hardship withdrawal and cap the number of loans a participant can take at one time

Legislative Updates 2012 to 2014


Change is in the Air: Proposed Definition of Fiduciary Rule

Proposed Rule Published

October 2010

Comment Period /

Hearings Extended Twice

Proposed Rule Pulled for

“Further Consideration”

Renamed the Conflict of

Interest Rule

Re-Proposal Expected

“Soon” . . .

WHO IS A FIDUCIARY?


Who is a Fiduciary?

A fiduciary is anyone “exercising any discretionary authority or control regarding the management or disposition of plan assets…”

ERISA §3(21)(A)

“A fiduciary is someone who has undertaken to act for and on behalf of another in a particular matter in circumstances which give rise to a relationship of trust and confidence.”

Bristol & West Building Society v Mathew


Types of Fiduciaries

Named Fiduciary – Someone specifically named in the plan document, or appointed by the plan sponsor

Functional Fiduciary – Someone who acts in a fiduciary capacity based on their job duties or responsibilities with respect to a plan

Individuals serving on investment committees, selecting service providers to a plan, and/or having influence or any discretionary authority over a plan are typically considered to be Functional Fiduciaries.


Do you exercise authority, control or influence in managing the plan?

Who chose the salesperson?

Who chose the product or service provider?

Who chose the investment options in the plan?

Who selects, monitors or replaces investment options?

Do you ever tell a participant how to invest their 401(k)?

Do you ever approve a broker’s recommendations?

Are You a Functional Fiduciary?


Fiduciary status is determined either: intentionally by being specifically named or appointed; or unintentionally by the functions one performs

Functions whereby one exercises authority, control or

influence over the plan are fiduciary functions: Hiring or firing service providers Selecting or changing investment options Making decisions, including approval of recommendations

A Fiduciary


Non-Fiduciary Service Providers

Record-keepers Insurance Agents

Third-Party Administrators

(TPA) Auditors

CPAs & Attorneys Stock Brokers =

“Financial Advisors/ Consultants”

Insurance Agents


Fiduciary Service Providers

Trust Company

Registered Investment Advisors

• Necessarily assumes non-ERISA fiduciary status under the Investment Advisor’s Act of 1940

Independent Fiduciaries who by contract assume:

• ERISA 3(21) Fiduciary Status • ERISA 3(38) Fiduciary Status


P-I-T

Fiduciary PLUS

Family Controlled Org

Employee Officer / partner

Service Provider




Employer

50% + owner







Union

50% + owner




Controlled Org



Parties In Interest


Duty of Loyalty “solely in the interest” of plan participants and beneficiaries “exclusive purpose” of providing benefits to participants and

beneficiaries and defraying reasonable expenses of the plan

Duty of Care Prudent expert standard Procedural prudence standard – focus on the process

Duty to “diversify plan investments” ERISA § 404 (a)(1)(C)

Duty to act in accordance with plan documents

What are ERISA Fiduciary Duties ?

FIDUCIARY RISKS AND RESPONSIBILITIES


The DOL can also access a civil penalty against a fiduciary who breached its duty or any person who knowingly participated in a breach in the amount of 20% of the amount recovered in a settlement with the DOL or awarded in a civil suit.

ERISA § 502(l)

Personal Liability

A fiduciary is personally liable for any losses the plan incurs by reason of its breach. A fiduciary who has breached its duty is liable to restore to the plan any profits the fiduciary made through its use of plan assets and for any other equitable or remedial relief deemed appropriate by the court, including removal of the fiduciary.

ERISA § 409


Damage to retirement security of plan participants

Financial ruin for you and other firm leadership

Criminal penalties including imprisonment: ERISA Section 501 contains criminal fines of up to $5,000

with potential imprisonment of up to a year. Sarbanes-Oxley increased these to a maximum of

$100,000 with potential imprisonment of 10 years.

Breach of Fiduciary Duty


Fiduciary responsibility carries personal liability.

There is no “corporate veil” for fiduciaries.

DOL Sanctions can be between 20%-50% of plan assets.

The 2008 LaRue decision permits individual participants to sue plan sponsors for fiduciary breaches.

The Plaintiff’s Bar sees over $3 trillion in US 401(k) assets.

There are potential criminal penalties including imprisonment.

Fiduciary Risk


Act solely in the interest of plan participants and their beneficiaries and with the exclusive purpose of providing benefits to them;

Carry out your duties prudently;

Follow the plan documents (unless inconsistent with ERISA);

Diversify plan investments; and

Pay only reasonable plan expenses.

Fiduciary obligations are among the “highest known to the law.”

Brussian v. RJR Nabisco, 5th Circuit Court, 2000

What is Fiduciary Responsibility?


Duty of Prudence – A fiduciary shall discharge his duties with respect to a plan solely in the interest of the participants and beneficiaries:

- with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent man acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims;

ERISA § 404 (a)(i)(b)

Duty of Exclusive Purpose – “A fiduciary shall discharge his duties. . . for the exclusive purpose of: (i) providing benefits to participants and their beneficiaries; and (ii) defraying reasonable expenses of administering the plan. . .”

ERISA §404(a)(1)(A)

ERISA Fiduciary Responsibility Overview


Duty to Diversify – A fiduciary must diversify investments so as to minimize the risk of large losses. Where participants make the investment decisions, at least three diversified investment options with materially different potential risk and reward characteristics must be available.

ERISA § 404 (a)(1)(C)

Duty to follow plan documents unless contrary to ERISA – A fiduciary must discharge his/her “duties in accordance with the documents and instruments governing the plan insofar as such documents and instruments are consistent with the provisions of Titles I and IV of ERISA.”

ERISA §404(a)(1)(D)



Duty to Avoid Prohibited Transactions

ERISA 406 (a)(1)(c) prohibits all transactions between a plan and a party in interest, and lists several specific transactions that constitute self-dealing or a conflict of interest. Existing ERISA 408(b)(2) provides exemptions to ERISA 406 (a)(1)(c) if three requirements are met:

The service must be necessary for the establishment or operation of the plan.

The service must be furnished under a contract that is reasonable. No more than reasonable compensation may be paid for the service.



“assure that the compensation paid directly or indirectly by [a plan to a service provider] is reasonable, taking into account the services provided to the plan as well as any other fees or compensation received by [the service provider] in connection with the investment of plan assets. The responsible plan fiduciaries therefore must obtain sufficient information regarding any fees or other compensation that [the service provider] receives with respect to the plans investments….to make an informed decision whether the [service providers] compensation for services is no more than reasonable.”

DOL - Frost (97-15A) and Aetna (97-16A)

“engage in an objective process designed to elicit information necessary to assess the qualifications of the provider, the quality of services offered, and the reasonableness of the fees charged in light of the services provided. . . such process should be designed to avoid self-dealing, conflicts of interest or other improper influence.”

DOL Field Assistance Bulletin 2002-3 (Nov. 5, 2002)

Reasonable Fees & Compensation


Plan Sponsor – “We aren’t changing our service provider; we’re with ABC Bank and we have our lending relationship there.”

Firm selling 401(k) products – “We only provide our clients with 401(k) products that pay us for ‘shelf space.’”

401(k) Product Provider – “We only include mutual fund options on our platform that pay us for ‘shelf space.’”

TPA – “I recommend XYZ 401(k)s; once we have $25 million with them they pay us an additional 10 bps override.”

Salesperson – “I recommend investment options that pay me a higher 12b-1 fee.”

Self-dealing, Conflicts of Interest or Other Improper Influence Affect Expenses


Assume that you are an employee with 35 years until retirement and a current 401(k) account balance of $25,000. If returns on investments in your account over the next 35 years average 7 percent and fees and expenses reduce your average returns by 0.5 percent, your account balance will grow to $227,000 at retirement, even if there are no further contributions to your account.

If fees and expenses are 1.5 percent, however, your account balance will grow to only $163,000.

The 1 percent difference in fees and expenses would reduce your account balance at retirement by 28 percent.

A Look at 401(k) Plan Fees, DOL, Employee Benefits Security Administration

Effect of Fees & Compensation


Rule 408(b)(2) Service providers receiving at least $1,000 must: Disclose all direct and indirect compensation it, or its affiliates or

subcontractors, receives. Provide a description of the services to be provided. Disclose whether they are providing any fiduciary services. Final regulation is effective as of July 16, 2011. It also includes a class exemption from the prohibited transaction

provisions for a fiduciary who enters into a contract without knowing that the service provider has failed to comply with its disclosure obligations.

Interim Final Service Provider Disclosure


Applies to “large plans” (100+ eligible participants) Compensation above $5,000 is reportable Compensation types Direct – Paid directly from the plan

Indirect – “Revenue Sharing,” investment management fees, finder’s fees, float revenue, brokerage commissions, securities lending revenue, etc.

Form 5500 Schedule C

CHALLENGES TO MEETING FIDUCIARY RESPONSIBILITIES


Plan Auditor says:

“There were no noteworthy issues found during our audit.”

TPA says:

“You’ve passed your ADP & ACP testing.”

Broker says:

“Morningstar gives all of the plan’s funds at least three stars.”

Employees say:

“We have no complaints about our 401(k).”

Plan Sponsor hears:

“I am squared-away!”

Fiduciary Expectation GAP


Fiduciary Expectation GAP

Fiduciary Non-fiduciary

Plan Sponsor

& Others (Have fiduciary responsibility and potential

liability)

Custodian (service provider)

Record-keeper (service provider)

CPA/Attorney (service provider)

Consultant(s) (service provider)

TPA (service provider)

Fiduciary Non-fiduciary Fiduciary Non-fiduciary


Many types of 401(k) sales people offer fiduciary education, advice or assistance, but then deny in writing fiduciary responsibility. For example: ABC Firm and ABC Firm Financial Advisors do not provide tax or legal advice, are not “fiduciaries” (under ERISA, the Internal Revenue Code or otherwise) with respect to the services or activities described herein, and this material was not intended or written to be used for the purpose of avoiding tax penalties that may be imposed on the taxpayer. Individuals are urged to consult their tax or legal advisor before establishing a retirement plan or to understand the tax, ERISA and related consequences of any investments made under such plan.

The Fine Print on “Fiduciary Warranties”


Mutual Fund Fees

• Operating costs listed in the fund’s prospectus and annual report – Reported as a percentage of funds assets – Deducted from your fund’s return, not out of pocket

MANAGEMENT FEE Fees paid to

investment Advisor for managing the

portfolio 0.50%

“OTHER” FEES General custodial, administrative, and

legal expenses

0.30%

12b-1 FEE Fee for distribution,

advertising and compensating

brokers 0.25%

SUB-TA FEE Paid to the TPA, record keeper or

used to offset plan fees

0.10%

EXPENSE RATIO 1.15%


• Annuity products charge a “wrap” fee: a fee layered on top of all the investments in the plan

• Typically this increases the Broker’s compensation • Determined at start of contract

MANAGEMENT FEE

0.50%

“OTHER” FEES

0.30%

12b-1 FEE

0.25%

SUB-TA FEE

0.10%

EXPENSE RATIO 1.15%

WRAP FEE Additional contract

asset charge 0.50%

= 1.65%

Annuity Products Charge a Wrap Fee


Revenue Sharing generally refers to a compensation practice in which money is paid to plan service providers out of the 401(k) investments, or by their managers (and affiliates). It can be straightforward, hard to find, or hidden. Here are just two types, the first of which is straightforward, and the second of which is sometimes harder to find:

12(b)(1) fees – Ongoing “trail” commission paid to sales company for distribution and service. Typically range between 0.25%-1% and deducted from fund assets.

Sub-TA fees (Sub-Transfer Agency) – Asset-based fee and/or a per-head fee and deducted from plan/fund assets. Intended to pay for administration performed by an intermediary (e.g. record keeper or TPA).

Revenue Sharing


ERISA § 404(c) “Employee-Directed Plans” relieve plan fiduciaries of responsibility for investment losses that result from the participants’ investment decisions. Plan qualifies if it provides the participant (1) the opportunity to

exercise control over the assets in his or her account, and (2) the opportunity to choose from a broad range of investment alternatives. 29 C.F.R. § 2550.404c-1(b)(1).

If a fiduciary conceals or misrepresents material non-public facts, the participant is not capable of exercising independent control.

However, the act of designating investment alternatives in an ERISA Section 404(c) plan is a fiduciary function to which the limitation on liability provided by Section 404(c) is not applicable. All of the fiduciary provisions of ERISA remain applicable to both the initial designation of investment alternatives and investment managers and the ongoing determination that such alternatives and managers remain suitable and prudent investment alternatives for the plan. Therefore, the particular plan fiduciaries responsible for performing these functions must do so in accordance with ERISA.

Investments: Employee Directed


Traditional defined benefit pension plans have limits on the amount of stock and debt obligations that a plan can hold. Generally not permitted to hold more than 10 percent of its

assets in employer stock 401(k) plans, profit sharing plans and employee stock

ownership plans have no limit on how much employer securities these plans can hold But only if the plan documents so provide

Investments in Employer Stock


If an employer decides to make employer stock an investment option under the plan, proper monitoring will include ensuring that those responsible for making investment decisions, whether an investment manager or participants, have critical information about the company’s financial condition so that they can make informed decisions about the stock.

Participants in individual account plans must be provided an opportunity to divest their investment in publicly traded employer securities and reinvest those amounts in other diversified investment options under the plan.

For employee contributions invested in employer securities, participants have the right to divest immediately.

Where employer contributions are invested in employer securities, participants can divest if they have 3 years of service. This does not apply to stand-alone employee stock ownership plans

where there are no employee or employer matching contributions.



A plan can buy or sell employer securities from a party in interest, such as an employer, an employee, or other related entity as described above (which would otherwise be prohibited) if it is for fair market value and no sales commission is charged.

However, when the employer’s stock suffers a precipitous decline in value, the loss of savings can trigger claims that the fiduciaries breached their duties by allowing the plan to continue buying company stock, permitting employer stock to remain an investment alternative for self-directed plans, failing to sell, etc., as financial conditions deteriorated.

Numerous cases involving fiduciary breach with respect to employer stock.



Employee Communications Late Deposit of 401(k) Deferrals and Loan Repayments Paying Expenses from Plan Assets

Other Challenges


Examine plan documents to determine fiduciaries named under plan

Identify functional ERISA fiduciaries Provide fiduciary training to plan fiduciaries Hold fiduciary meetings and document meetings and other

decisions in detail Determine which fiduciary responsibilities have been

delegated and monitor delegates Examine whether fiduciary liability insurance is adequate Perform an ERISA Section 404(c) analysis with respect to

401(k) plan Examine plan fees, including those paid out of plan assets Consult with experienced ERISA legal counsel

Overcoming the Challenges

PRACTICAL CONSIDERATIONS


Prudent Process

ERISA measures the process…

Not necessarily the result…


First step in Prudent Process Most fundamental fiduciary function Supports the “paper trail” Keeps investment process intact during market volatility Provides working framework for fiduciaries Sets guidelines for making investment decisions Negates “Monday morning quarterbacking”

Prudent Process Investment Policy Statement


An employer should establish and follow a formal review process at reasonable intervals to decide if it wants to continue using the current service providers or look for replacements.

When monitoring service providers, actions to ensure they are performing the agreed-upon services include: Evaluating any notices received from the service provider about

possible changes to their compensation and the other information they provided when hired (or when the contract or arrangement was renewed);

Reviewing the service providers’ performance; Reading any reports they provide; Checking actual fees charged; Asking about policies and practices (such as trading, investment

turnover and proxy voting); and Following up on participant complaints.

Monitoring a Service Provider


“Unless they possess the necessary expertise to evaluate such factors, fiduciaries would need to obtain the advice of a qualified, independent expert.”

DOL Reg. § 2509.95-1(c)(6) “…where the trustees lack the requisite knowledge, experience and expertise to make the necessary decisions with respect to investments, their fiduciary obligations require them to hire independent professional advisors.”

Liss v. Smith, 991 F.Supp. 278, 297 (S.D.N.Y. 1998)

Prudent Expert


Lessons Learned from…

Enron

Fee Litigation cases Tibble v. Edison

Tussey v. ABB, Inc. International Paper George v. Kraft Foods


Types of Trustees

Directed versus

Non-Directed


Co-Fiduciaries

What is a co-fiduciary?

Examples

Responsibilities


ERISA section 402(c) allows for a plan sponsor to delegate fiduciary responsibility. A prudently selected and appointed fiduciary can alleviate a plan sponsor from nearly all fiduciary liability. The one residual fiduciary responsibility is to monitor the performance of the appointed fiduciaries.

An Investment Manager under ERISA 3(38)

An Independent Fiduciary under ERISA 3(21)

Fiduciary Delegation


Prudent Expert ERISA 3(21)(A)(ii)

Plan

Sponsor

Fiduciary Advisor

ERISA

3(21)(a)(ii)

Custodian (service provider)





Fiduciary Delegation ERISA 3(38)

Plan Sponsor

ERISA 3(38) Investment Fiduciary Custodian

(service provider)




Formal Appointment


Plan Sponsor Fiduciary Line of Defense


Fiduciary Delegation ERISA 3(21) Full Scope

Plan Sponsor

ERISA 3(38) Investment

Manager Custodian

(service provider)




Formal Appointment


Plan Sponsor Fiduciary Line of Defense

ERISA 3(21)

Full Scope Fiduciary

Formal Appointment


Retirement plan audit Required for large plans (generally greater than 100 participants) The purposes is to render an opinion on financial data for your plan

Plan financials present fairly in all material aspects, are in conformity with GAAP

Involves understanding Plan Design and implementation of controls related to material account

balances and major transaction classes Detailed testing of plan’s investment accounts and transactions (full

scope audit only) Certain tests of compliance with plan and regulatory requirements are

part of the audit procedures

The audit of your plan’s financial statement is NOT designed to be a COMPLIANCE AUDIT

Audit Versus a Fiduciary Review


Fiduciary review Provides additional oversight and review necessary to ensure plan

fiduciaries are providing participants the highest quality retirement plan, while managing their fiduciary liability exposure

Not mandated but recommended Fiduciary assessments address the fiduciary decision-making

process and due diligence procedures, particularly related to plan investment options and expenses

They can also be designed to review current administrative practices for compliance with plan document

Fiduciary assessment helps you demonstrate successful management of the plan’s fiduciary process

They DO NOT RENDER AN OPINION on the accuracy of FINANCIAL DATA

Audit Versus a Fiduciary Review


SUMMARY

Identify and educate plan fiduciaries Confirm in writing fiduciary and non-fiduciary service

providers Maintain a “Prudent Process” Discover and evaluate all fees and compensation Retain a Prudent Expert Delegate to an Independent ERISA 3(38) or 3(21) Fiduciary Monitor and document Fulfilling one’s fiduciary duties enhances the probability of

retirement income security for one’s participants Failure in fulfilling one’s fiduciary duties could be a

catastrophic event causing financial ruin for the fiduciary

RESOURCES


Department of Labor Fiduciary education:

http://www.dol.gov/ebsa/fiduciaryeducation.html Webcast: Getting it Right..Know Your Fiduciary Responsibilities: Part I, II &III

www.dol.gov/ebsa/newsroom/webcasts.html

AICPA – Employee Benefit Plan Audit Quality Center http://www.aicpa.org/InterestAreas/EmployeeBenefitPlanAuditQuality/Pages/E

BPAQhomepage.aspx

Bright Scope Rating Your 401(k):

www.brightscope.com

Fiduciary Resources

http://www.dol.gov/ebsa/fiduciaryeducation.html

http://www.dol.gov/ebsa/newsroom/webcasts.html

http://www.aicpa.org/InterestAreas/EmployeeBenefitPlanAuditQuality/Pages/EBPAQhomepage.aspx

http://www.aicpa.org/InterestAreas/EmployeeBenefitPlanAuditQuality/Pages/EBPAQhomepage.aspx

http://www.brightscope.com/


Questions?


Join us for these courses: 12/9 & 12/17: Understanding Your Employee Benefit Plan’s

Investments

Read these related publications: Whitepaper: Plan Sponsor's Guide to Retirement Plan

Investments Employee Stock Ownership Plan Primer

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Webinar Slides: Understanding Your ERISA Fiduciary Responsibilities

Economy & Finance