In the meantime, plan fiduciaries should consider what steps they might take to defend against an enforcement action by the
DOL. First, a plan fiduciary should understand and document what procedures it has in place, either directly or through a plan service provider, to address these issues.
The state DOLs were fairly welcoming and didn't ask us to do anything different than we had with the federal
DOL. Frank A.
In sum, despite all of the uncertainty, the only pronounced undoing of the rule has come at the hands of the
DOL. Ironically, it appears that the greatest threat to the future of the rule may not be the retirement services industry, but the DOL itself.
The AICPA Personal Financial Planning membership section is coordinating the seminars in partnership with the
DOL. AICPA material related to the Institute's 360 Degrees of Financial Literacy campaign is being distributed at the seminars, and state societies are branding events as financial literacy activities because they involve the protection of employee retirement and health benefits--important elements of the AICPA nationwide financial literacy program.
However, the cost of correcting problems is often significantly higher if the violation is discovered after a period of time or by the IRS or
DOL. Remember.
However, DOL has also raised issues of concern to the TSP Board, in addition to making recommendations, where the TSP Board has not resolved the issue with
DOL. In these instances, there is no formal process with which to ensure that the TSP Board is held accountable for these actions.
Ultimately, I discovered that several of the problems I encountered were the result of my own failure to properly model the type of collaborative discourse I would like to see in the online environment through
DOL.Employers should not take these requirements lightly, as they are strictly construed by the
DOL.