[10912]
April 19, 1999
TO: PENSION COMMITTEE No. 28-99
AD HOC COMMITTEE ON UNIFORM 401(K) PLAN FEE DISCLOSURE FORM
RE: 401(K) PLAN FEE DISCLOSURE FORM
______________________________________________________________________________
As you are aware, the Department of Labor has requested that the Institute, the American
Council of Life Insurance (ACLI), the American Bankers Association (ABA) and the Profit
Sharing/401(k) Council of America (PSCA) work together to develop a uniform fee disclosure form for
401(k) plan fees. Each of the associations has developed a draft disclosure form with the assistance of
its members. The associations have met several times this year to discuss the format of the uniform
401(k) fee disclosure form. Recently, the ACLI, ABA and PSCA agreed to use the Institute’s draft
disclosure form as the basis of the uniform fee disclosure form.
As a result of comments from the ACLI, ABA and PSCA, the Institute’s draft disclosure form
has been modified as follows: (1) Schedule A includes charts for Brokerage Window, Other Product and
Other Product-Related Charges and Expenses; (2) Schedules B, C and D contain a column for
“rate/estimate” (to indicate the method of calculation of the plan expense) and “total cost” (to indicate
the total cost of the service, including the flat rate charge); and (3) Schedule E contains a complete list of
definition of terms.
The associations have agreed to circulate the revised draft of the Institute’s disclosure form to
their members for comment. Attached for your review is a copy of the revised draft of the Institute’s
uniform 401(k) plan fee disclosure form. Please review the revised draft of the 401(k) plan fee
disclosure form and forward your comments to either myself or Russ Galer by COB Tuesday, May 4,
1999. You may fax your comments to (202) 326-5841, email them to ricard@ici.org or rgaler@ici.org.
In the alternative, you may call me at (202) 218-3563 or Russ Galer at (202) 326-5835 with comments or
questions on the revised draft disclosure form.
The associations have scheduled a follow-up meeting in mid-May to discuss their member
comments on the uniform 401(k) fee disclosure form.
Kathryn A. Ricard
Assistant Counsel
Attachment