The 404 disclosure is by far the easier of the two required disclosures for you to get your hands on. It’s the one designed for plan participants and it should be delivered on a periodic basis. It will include all the fees reported by your 401 plan’s various service providers to your company.
While a little bit harder to read, the 408 disclosure that goes directly to the plan sponsor contains far greater detail. Unfortunately, the DOL provided no template in the final Rule for this fee disclosure. As a result, there’s no way to say for certain what is disclosed, where it’s disclosed and how to interpret the data that is disclosed.
Here’s the problem with all these DOL required disclosures: there’s no guarantee you’ll see all the fees. The most effective way to uncover any potentially “hidden” fees is to go directly to the documents provided by the investment companies themselves.
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