Due to new interpretations of its regulations by the Department of Labor (“DOL”), additional disclosure is now required for many retirement accounts effective January 31, 2022. Under these new changes, qualified plans require further disclosure regarding potential conflicts of interest and issues related to fiduciary status. Our current Form CRS and the Reg BI Disclosure provide sufficient disclosure to meet the new requirements for qualified plans.
Effective January 31, 2022, Form CRS and the Reg BI Disclosure will be required forms for all qualified plan business including:
- New and existing qualified plans that are changing vendors
- Existing qualified plans that are changing broker/dealers
Form CRS and the Reg BI Disclosure are to be left with the client (plan trustee) and do not need to be submitted to ESI for review. These documents are automatically included in new business work items for new 401k accounts that are created using Docupace/Starting Point and will therefore automatically be given to the client and ESI.
When the client/trustee signs the Customer Agreement, they acknowledge that they have received Form CRS. The Acknowledgement of Form CRS Delivery DOES NOT need to be submitted. This Acknowledgement is only required when making a recommendation prior to providing account paperwork (which triggers the Form CRS delivery requirement to a prospective customer).
Questions? Give ESI Operations a ring at 800-344-7437!
Click Here to View Field Notice 2022-03: Additional Disclosures Required for Qualified Plans
TC125236(0122)1