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Brokerage Accounts and 404a-5: Making Sense of the Rules
Presentor: Stephen Forbes Recorded Date: 8/9/2012 Duration: 100 Min.


This program was recorded during a live presentation on August 9, 2012.

The deadlines for the first annual (for most plans August 30) and the first quarterly (November 14) participant fee and investment disclosures are fast approaching. For a plan that provides the traditional platform of investment options, the new requirements impose significant and burdensome responsibilities on plan administrators. When the plan adds brokerage accounts as an additional investment option or as the only investment option, the requirements differ and become more complicated.

Brokerage accounts raise numerous questions that do not apply to traditional arrangements:

  • Is the brokerage account subject to the investment disclosures?
  • Is a plan with only brokerage accounts subject to any of the new disclosure requirements?
  • Are the investments selected within the brokerage accounts designated investment alternatives (DIAs)?
  • How does a plan comply with the investment disclosures if the plan has no DIAs?
  • Is an employer providing plans with unlimited investment options in compliance with the fiduciary requirements?
  • What brokerage expenses are subject to disclosure?
  • Can the plan satisfy its expense disclosure requirements via the monthly brokerage statement?
  • Must the employer now monitor what investment options the participants select in the brokerage accounts?
This Web seminar answers these questions and more that practitioners have regarding the application of the participant fee regulations and the new guidance (FAB 2012-2) to brokerage accounts. This program is vital to anyone advising a plan that includes or is contemplating brokerage accounts as an investment option.

Topics include:

  • DIA definitions and exemption.
  • Brokerage account investments.
  • Brokerage account expense disclosures.
  • Investment disclosures.
  • Investment disclosures: Plan with no DIAs.
  • Comparative chart requirements.
  • Web site requirements.
  • Monitoring investments in brokerage accounts.
  • Fiduciary responsibilities.
  • Disclosure through brokerage statements.

Prerequisites: There are no prerequisites or other advanced preparation for this program. However, the instructor assumes participants are generally familiar with the participant fee disclosure requirements under the 404a-5 regulation.

Level: Intermediate

Instructional Delivery Method
Recorded playback of a live presentation.

Speaker: Stephen W. Forbes, J.D., LL.M.
Author of The 5500 Filing Guide

Objectives: After participating in this program, attendees should be able to:

  1. Determine which (if any) investments under a brokerage account are DIAs.
  2. Determine whether disclosures in monthly statements comply with the new regulations.
  3. Explain what items must appear in annual and quarterly participant reports.
  4. Assist plan administrators in understanding how to comply with the new rules if the plan offers brokerage accounts.
  5. Determine which investments must be disclosed on the comparative chart.
  6. Explain the fiduciary standards which apply to a plan with unlimited investment options.

Hardware System Requirements:

  • Windows 95, 98, NT 4.0, 2000, XP, Windows 7
  • Internet Explorer 4.01 or later, Netscape 4.08 or later, and set Internet browser to allow pop-up windows.
  • High-speed Internet connection.
  • Pentium 166+ MHz, 128MB RAM or more.
  • 1023 x 768 or higher display resolution.
  • Soundcard and Speakers.

Software Requirements:

Recorded Event Time Limitation:
This recorded event will be available for 20 days from your date of registration.

Program related requests, questions, or concerns may be emailed to: