ASPire launches Definitive DisclosureSM
Since our beginning, ASPire has practiced fee transparency and focused on increasing awareness among Plan Sponsors and plan participants regarding fees charged to retirement plans. So we are extremely well-positioned to welcome the DOL regulations in regard to fee disclosure through the implementation of our Definitive DisclosureSM program that not only meets but exceeds the regulatory requirements.
With the goal of making fee disclosure simple for all ASPire clients, we offer a variety of resources, including How-To Guides which describe the steps required in the recordkeeping system to enjoy the full benefit of the Definitive Disclosure program.
ASPire does not charge its clients for the use of the Definitive Disclosure program. Yet the benefits are substantial:
Advisors, TPAs and other covered service providers can disclose their fees to Plan Sponsors by setting up provider and billing profiles in an easy-to-use format.
Once their providers have completed their provider and billing records, Plan Sponsors will be able to download, print and deliver to participants a summary of all fee disclosures in a readily understandable report.
All covered service providers will be able to take control of their own billing, starting with 3Q2012 billing, including moving from quarterly to monthly billing, if desired.
You can take action now! TPAs/Advisors: Be sure that you and the other service providers on your plans have completed the Covered Service Provider (CSP) Profile through ASPire’s Definitive Disclosure program. If your Profiles are in place, it will be much easier for your Plan Sponsors to fulfill their 404(a)(5) obligations.
Click here to download the How To Guide for Advisors.
Click here to download the How To Guide for TPAs.
Plan Sponsors: Ensure that all of your service providers have completed their Covered Service Provider (CSP) Profiles through ASPire’s Definitive Disclosure program. If they have not completed their Profiles, they can do so now and you can re-run the Notice to include them. Alternatively, they will need to provide you with their own disclosures for you to provide to your participants. Once you have all the disclosure information you need, you need to print and deliver it to your participants.
Click here to download the How To Guide for Sponsors.
HOW TO GET MORE INFO
There are several resources available to you, whether you are a TPA, Advisor or Plan Sponsor.
Click here to watch a one hour webinar presented by James Olson, the architect of Definitive Disclosure. (PC users may need to download the GoToMeeting codec. If you have difficulty downloading the webinar, you may need to try a different browser.)
The webinar presentation is summarized in these 3 How-to Guides:
From mid-June 2012 through 2Q2013, what are the major milestones?
6/21 CSPs were able to input their Profiles and Fee Templates and generate their own CSP Report.
7/1 Plan Sponsors were able to generate their Service Provider Profiles Report and their Fee Disclosure Report.
8/17 Plan Sponsors were able to generate the Summary Plan Disclosure Notice for delivery to Participants by 8/30.
10/1 404(a)(5) - compliant participant statements were generated & mailed by the end of October.
Future Enhancement: Activate billing module.
What are the steps in the process for generating Definitive Disclosure reports?
First, CSPs must enter their CSP Profile(s). Then they must create their Fee Template(s). Finally, they need to associate them with their plans.
Is it possible to just import our information?
An import is not available at this time. However, creating a CSP Profile by just inputting the information via the website is simple and straightforward and would take far less time than an import process.
Are there conventions/samples for service descriptions?
We have provided some examples in the How To Guides. You can request a Guide from the How To Get More Info section.
Can we create a single profile and assign it to more than one plan?
Yes. A single profile as well as a single fee template can be assigned to more than one plan. CSPs have the flexibility to create any number of profiles and fee templates in order to reflect their business practices.
Can this system be used for plans that are not yet on the ASPire platform?
No. ASPire’s Recordkeeping System houses all the data for Definitive Disclosure, so a plan would have to be on the ASPire platform to use Definitive Disclosure.
Are most TPAs handling the CSP Profile setup for the Advisors, or are they pushing that out to the Advisors?
This will depend on the relationship between the TPA and the Advisors. If the advisor is acting as a CSP in the Plan it is recommended that they complete their own CSP Profiles and Billing Records.
Are the categories customizable? Are the PDF reports, like invoices, editable?
No. We may do future system enhancements to expand the categories, but the PDFs will not be made editable.
Will ASPire pre-populate the current information you have on providers?
No. Providers must input their information. This is because, while ASPire is providing the facility for providers to disclose to their clients, the information you input needs to come from you so you can be sure that the information you want to convey is presented exactly as you want it.
For the sections like insurance, if left blank, will the tag "Insurance" appear on the report or be omitted?
Only the CSP Profiles stored in the system will be populated on the Summary Service Provider Report
When we enter our fees through the CSP Process, will they be included in the disclosures?
Yes. The billing record invoices tied to a CSP Profile will be included in the Reports and online.
How are you handling self-directed brokerage accounts through ASPire?
We have a flag indicator for SDBAs and can run fees against accounts with this flag. The underlying investments and trading fees of SDBAs are not subject to the 408(b)(2) regulations.
Any recommendations for billing record conventions (client name, fee %, etc)?
Please see the sample billing record naming conventions in the sample reports.
Do I understand correctly that, beginning with 1Q2013 billing, I will have control over my own billing through the ASPire platform?
Yes. Billing for 4Q2012 will be the last billing cycle that will use the current process. For CSPs to be paid for fees associated with plans on the ASPire platform, it is required that each CSP create profile(s) and fee template(s) and associate those with their plans. Beginning with the 1Q2013 billing cycle, CSPs must submit their own invoices.
So the 3 steps are: CSPs will need to create their CSP Profiles and Fee Templates, then associate them with the plans, then generate invoices. Is that correct?
Yes. Once CSPs have provided this information, the ASPire system will automatically calculate fee amounts (including annualized and pro-rated fees) and generate invoices.
Just to confirm... the automated quarterly payments I receive now will no longer happen, and I will need to process these myself each pay period?
Correct. As a CSP you will generate the billing records to Plans directly on the system. The automated process can still occur, but it will now be drawing from the Definitive Disclosure data when you initiate billing transaction.
If an advisor is paid through 12b-1, is ASPire providing the disclosure within the sponsor notice, and secondly, the participant disclosure?
Indirect 12b-1 compensation is captured and reported in the Definitive Disclosure program. Advisors receiving compensation in this manner will need to complete a CSP Profile for disclosure purposes. They will NOT be running billing records against the Plan accounts. Detailed 12b-1 compensation will be displayed in the Fee Summary report automatically.
Will a TPA be required to set up a CSP profile so that they can bill (even if they take NO indirect compensation)?
No. However, ASPire recommends that a TPA set up a CSP profile, even if they take no indirect compensation, as Definitive Disclosure was designed to provide total fee information.
So, because we are in control of our own billing, does this mean that we can switch to monthly billing?
Can the system deal with a min fee calc ?
How does the system deal with a client that has 1/2 of their fee deducted from participant accounts, and 1/2 paid by check by the Plan Sponsor?
In the Plan Sponsor Payment Method section, Plan Sponsors may elect to pay any fees that encompass the methods stated above.
Does the Plan Sponsor have to go in and approve a bill in order to get it paid, or is it unilateral based on our advisory agreement?
Plan Sponsors will either have to set up Auto-Pay for certain fee payments, or they will have to approve each invoice.
Will TPAs and Advisors be able to view the ERISA and/or Forfeiture account balance, or is this just viewable by Plan Sponsors?
Right now, only Plan Sponsors have this view, but this could be a future enhancement.
Are Plan Sponsors going to be required to go into the system and decide if they are going to auto-pay the CSPs?
Yes. Definitive Disclosure empowers the Plan Sponsor to decide which fee invoices they will Auto-Pay and which ones they will review before approving.
If Plan Sponsors have always been writing checks to a CSP, should they go in and enter bills (the CSP and sponsor) so that the summary report will list all fees relating to the plan?
Yes. We recommend that the Plan Sponsor enter this information, as Definitive Disclosure was designed to provide total fee information.
How quickly is payment remitted to the CSP?
If the fee has been designated Auto-Pay by the Plan Sponsor, it should take only 5 business days. Otherwise, it depends on how quickly the Plan Sponsor approves the invoice.
How will fee transactions previously paid this year be reflected on the reports?
Any fee paid will still show up. ASPire will map the fees to the Form 5500 codes so nothing is lost.
Will each service provider be responsible for entering the billing info and generating invoices? For example, we are the advisor. Would we do this billing, or is the TPA/Recordkeeper processing this as in the past with info we provided?
While service providers can make arrangements among themselves about exactly how the information is input, it is the responsibility of each service provider to ensure that their information is entered accurately.
If we get paid from plan assets from ASPire, is ASPire billing the plan on our behalf? Or is ASPire just pulling the payment out of plan assets per the Plan Establishment documents?
As a CSP of the Plan you will need to create a CSP Profile and associated billing records to process invoice payments with your Plans.
How will Plan Sponsors be notified of this?
ASPire respects the relationship between CSPs and their Plan Sponsors and plans to let CSPs communicate with and educate their Plan Sponsors. That said, ASPire is happy to talk with Plan Sponsors in coordination with CSPs.
What resources are available for Plan Sponsors?
Plan Sponsors can
Request the How To Guide for Sponsors (See the link above in the How to Get More Info section)
Contact their Relationship Manager at email@example.com.
Contact ASPire Sales at firstname.lastname@example.org.
Contact ASPire Client Services at 866.634.5873.
Once we enter our CSP profile as an Investment Advisor, can one of the reports that are available be run and sent to each Plan Sponsor as our disclosure by 7/1/12?
Yes. Once you have entered your information and associated your profile(s) and fee template(s) with your plans, you can generate your disclosure report and sent it to the Plan Sponsor.
Can service providers assist Plan Sponsors with setting up billing?
Setting up billing is the responsibility of the CSP. The Plan Sponsor then has flexibility in regard to Revenue Sharing, Auto-Pay and Payment Method, for example. And CSPs can certainly help Plan Sponsors with those decisions, or refer them to ASPire Client Services at 866.634.5873.
May Plan Sponsors enter their own CSP Profiles? For example, they have hired an ERISA attorney.
ASPire will set up additional CSP Profiles requested by Plan Sponsors. Please contact Client Services for assistance at 866.634.5873.
How will Plan Sponsors see ASPire info? Will ASPire make available ASPire’s own disclosures for clients/sponsors?
ASPire is a participating CSP and will utilize the Definitive Disclosure program in the same manner as other CSPs. ASPire CSP Profiles will be viewable in the Service Provider Profiles Report and also via the PROFILES module in the system.
What if I am a subadvisor? Do I create my own CSP Profile?
First, you need to ask “Am I the CSP in this situation, according to the DOL?” If you are, then you need to create your own CSP Profile. If not, then the CSP to which you are the subadvisor has to disclose the nature of your relationship.
Where will Plan Sponsors find the Service Provider Profiles report?
The Service Provider Profiles report is located in the REPORTS module of the Plan Sponsor Gateway.
Is there an email address I can send to ask ASPire to contact Plan Sponsors?
Yes. Please email your client relationship manager or email email@example.com
Who teaches the Plan Sponsors how to pay invoices and use the site?
ASPire will assist Plan Sponsors with training using the Definitive Disclosure program.
Most Plan Sponsors are not aware of these changes. We as the IA have been educating them. Is training available to Plan Sponsors?
No special Plan Sponsor training is planned at this time. Plan Sponsors are encouraged to download the How To Guide for Sponsors and call Client Services for help if necessary.
Will our Plan Sponsors have access to an updated User Guide and support materials and how/when will they get it?
Yes. Support materials will be available in the Document Library for every Plan.
Will ASPire be sending out the 408(b)(2) disclosure reports electronically or via mail?
Disclosure reports are available electronically. ASPire will not be mailing reports to Plan Sponsors.
Is the quarterly participant statement going to cover the 404(a)(5) requirements?
No, not by itself. This is because it is not possible to include the necessary benchmark indices for each investment option in each statement. The 404(a)(5) requirements are met through a combination of the quarterly participant statement and the Summary Plan Disclosure Notice.
How will the annual Summary Plan Disclosure Notice be distributed? Will ASPire be mailing this out to the participants receiving quarterly statements or all participants on the RK system?
No, ASPire will not be mailing the Summary Plan Disclosure Notice. It is the responsibility of the Plan Sponsor to provide the Summary Plan Disclosure Notice to participants. Sponsors can download the Notice from the REPORTS tab in the ASPire system for printing and delivery.
Is there any other way for participants to see the Summary Plan Disclosure Notice rather than waiting for delivery from the Plan Sponsor?
Not at this time. An upcoming systems enhancement, though, will enable participants to view and download the Summary Plan Disclosure Notice from the REPORTS tab in the online Plan Participant Gateway. Projected for 1Q2013
Are Plan Sponsors required to print and distribute the Summary Plan Disclosure Notice reports to all plan participants, or can they meet the reporting requirement by providing the online access?
We recommend taking the conservative approach that online access is not sufficient. Plan Sponsors should print and deliver the Summary Plan Disclosure Notice to participants.
Does it have to be the Plan Sponsor which distributes the Notice, or can the TPA or Advisor do it?
The TPA or Advisor can certainly distribute the Notice, but it is the responsibility of the Plan Sponsor to ensure that participants receive the Notice each year by the August 30th deadline.
How will the ASPire system provide benchmarks, turnover, costs, etc. for model portfolios? Will advisors using model portfolios that are considered DIAs be required to submit model and benchmark returns data?
If the model is built from investment options in the core lineup, Definitive Disclosure will meet the disclosure requirements.
If the model uses any investment options that are NOT in the core lineup, this creates a separate Default Investment Alternative (DIA). ASPire will not be doing these calculations in the initial roll-out of Definitive Disclosure, but we will work with advisors to find a way to meet the requirements. Please contact Mike Gottfried at firstname.lastname@example.org for assistance.
Why do the investment models that we use for our 401(k) plans have such a high allocation to “Other” on the Summary Plan Disclosure Notice on the Model pie chart?
The pie charts represent up to 6 funds. If the portfolio has 6 or fewer funds, they’ll all show up. But if the portfolio has more than 6 funds, the chart displays the 5 with the highest allocations and then combines all the funds with the lowest percentages into the “Other” category. So there will never be more than 6 slices in the pie in the chart.