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Hewitt Submits Comments on Interim Final Rule on Reasonable Contract or Arrangement Under Section 408(b)(2) — Fee Disclosure


On August 27, 2010, Hewitt submitted comments to the Department of Labor's Employee Benefits Security Administration (EBSA) on the interim final rule on reasonable contracts or arrangements under Section 408(b)(2) of the Employee Retirement Income Security Act (ERISA).

The interim final rule was published in the Federal Register on July 16, 2010.

Hewitt's comment letter, linked to below, requests the clarification of, enhancements, and additions to the rules in the following areas:

  • Recordkeepers and brokers should not be liable for the accuracy of fee information of unaffiliated designated investment alternatives;
  • Suggestions for summary disclosure statement;
  • Compensation that must be disclosed should be expanded to include compensation earned from cross-selling;
  • Responsible plan fiduciaries should not be obligated to investigate the sufficiency of service provider disclosures;
  • Suggestion of annual disclosure statement;
  • Brokerage window disclosure;
  • Clarification needed for covered service provider description; and
  • Effective date.

Hewitt Submits Comments on ERISA 408(b)(2) Interim Final Rule