Several weeks ago I reported on the fi360 conference session in which Fred Reish shared his thoughts on 408(b)(2) – the DOL's new Fee Disclosure Rule that becomes effective next week. Reish and others expressed the concern that bundled service providers are sending or planning to send naïve plan sponsors an avalanche of paper.

This week I wrote a story from the perspective of independent service providers responsible for reporting those fees to give 401(k) plan sponsors a sense of what they might see from this type of vendor. The differences are stark and may indicate a new marketing battleground that every 401(k) plan sponsor should be aware of. 

First, let's start with the reality that every 401(k) plan sponsor has the fiduciary duty to do what's best for plan participants. We can argue later if all plan sponsors actually embrace this theory in practice, but we can all agree that, in theory, this is their primary function as a plan fiduciary.