Phia Group Russo & Minchoff

Application of the Service Provider Fee Disclosure Regulations to Third Party Administrators

Third party administrators (TPAs) are struggling to determine if and how the new service provider fee disclosure regulations will affect their practices. Many TPAs have determined that they are not subject to the disclosure requirements because they receive their compensation directly from the employer or from the plan. TPAs that have made such determinations may, nevertheless, have concerns because they may receive unanticipated indirect payments from financial institutions to which they refer business. In this technical update, we will discuss how a TPA deals with unanticipated indirect compensation. 


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