The Principal Life Insurance Co. wanted to know: Should revenue-sharing payments it receives for services rendered to an ERISA plan be considered part of the plan's assets?
The Department of Labor provided an answer in Advisory Opinion 2013 03A.
Principal provides record-keeping and other administrative services to various ERISA qualified plans. It also provides investment options that include its own insurance company accounts and unaffiliated mutual funds. It receives revenue-sharing payments from these funds and retains them in Principal's general asset accounts; it doesn't establish a special custodial account for receiving these payments. It then draws on these funds to pay for services to the plan.
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