SURVEY SAYS: Are you ready for fee disclosure rules?

Last week, I asked NewsDash readers, "are you ready for fee disclosure rules?"

Nearly one-third (31%) of those who responded indicated they are ready and have all processes in place. Sixty-two percent said they are working on it and will be ready in time for the deadline, and 7% indicated they are working on it, but probably will not be ready by the deadline. None of the NewsDash readers who responded said they are not ready.  

I also asked readers what they think is the hardest part about getting ready for provider fee disclosures. The number one answer, selected by 38% of respondents, was coordinating data from multiple places. Twenty-four percent indicated the hardest part getting all data in the required format. Fourteen percent selected “figuring out the exact fee for certain services or investment types,” and 7% chose “anticipating questions from plan sponsors.”  

Among “other” responses:  

  • “As a plan sponsor, determining who is a covered service provider,” 
  • “Getting correct indirect compensation formula from the daily recordkeeper,” and 
  • “Trying to make heads or tails from the information we’re given.” 

As for the hardest part about getting ready for participant fee disclosures, the largest percentage of respondents (36%) said it is getting all the data in the correct format, followed by 21% who selected “anticipating plan participant questions.” Eighteen percent said the hardest part is coordinating data from multiple places, and 11% said it is figuring out the exact fee for certain services or investment types.  

Among “other” responses: 

  • “Getting over the hurdle of perception,” 
  • “As a plan sponsor, trying to anticipate if this will be big noise or little noise to our participants. That is, what will be their reaction?” 
  • “Dealing with parties who are clueless about the disclosure requirements. Apologizing for requirements like the glossary of investment terms,” and 
  • “Not knowing what it would be, when it would be, and how it will be received.” 


In the verbatim comments, NewsDash readers expressed thoughts that participants will not even read the disclosures provided, or will question what it is and why they are getting it. Several expressed a distaste or doubt about the rules.


The blind leading the blind off the cliff.  

We are so ready for it, I'm tired of hearing about it and so are most of our clients.  

I'm trying not to dread the WTF questions that I know we'll get. Explaining that the fees haven't changed from what they were before is going to be interesting.  

Rank and file participants won't even notice it.  

Are we just lucky since our plan provider is working on this for us?  

A good concept gone awry.  

We're spending a lot of time on something few will read. Biggest question we anticipate is "Why am I getting this?"  

I HATE IT - I'm the one that will get all the phone calls and complaints, just like for every other required government notice. If only we could create these things in plan English that everyone can understand it would help.  

Our plan receives no employer financial or administrative support. 100% of financial support for administrative and finacial servies comes from participants. Thus, we have viewed monitoring and knowledge of plan costs as a responsibility. Participants have a right to this information because it is they are the ones paying the bills. We are pleased to pass the information on to them.  

We think we're ready, but are starting to wonder if our vendors are!  

A lot of work is going into something that most participants will not even read.  

Any suggestions for a sample Master Service Agreement would be greatly appreciated.  

Just by luck, I'm on vacation the when they're scheduled to come out, yee-haw! Haven't even left yet and it's already the best vacation ever!  

Disclosure - MEANINGFUL disclosure is a good thing, and long overdue. That said, anyone who thinks that this new wave constitutes meaningful disclosure - well, I hope they're right and I'm wrong...