Michael A. Webb, Vice President, Retirement Plan Services, Cammack LaRhette Consulting, answers:
Excellent and timely question, and please indulge the Experts in commencing this response by wishing all (b)lines readers a Happy Halloween! As for tricks, the Experts need look no further than the recent government shutdown. Although key filing deadlines, such as the 2012 extended 5500 deadline of 10/15 for calendar-year plans, were not delayed, there were many other delays associated with the shutdown, from the delay in announcing the contribution and benefits limits for 2014 to a delay in plan sponsor access to recently filed 5500s on the EFAST website, since items such as the audit report must be reviewed to ensure that no confidential participant information is present prior to posting on EFAST.
In addition, though no announcement has been made with regard to the progress of the 403(b) plan document prototype program, given the fact that the IRS has already delayed other key calendar dates, such as the earliest date 2013 personal income tax returns may be filed, it is expected that there will be a delay in the review process for vendor prototype submissions as well.
On the treats side, increased access to fee information via the vendor and participant fee disclosures, as well as to fee benchmarking via the 5500 information available in plan sponsor filings on EFAST, has enabled plan sponsors to not only account for fees in a more comprehensive fashion than ever before, but to be in a more informed position to negotiate fees with their service providers. In addition, the wealth of plan information available via EFAST has also enabled plan sponsors to more effectively benchmark their plans in other areas, such as services and plan design. Never before has so much information been available in such a timely fashion.
NOTE: This feature is to provide general information only, does not constitute legal advice, and cannot be used or substituted for legal or tax advice.
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