Disclosure Reviews

Disclosure Review of Service Providers

This review will give you a deeper understanding of how investment advisers, recordkeepers, third party administrators, etc. service your plan. It provides complete documentation of a due diligence process for the determination of whether fees are reasonable for the services provided.

Provided by an independent fiduciary expert, the review uses commercially available benchmarking services, combined with qualitative analysis so the plan sponsor can reach its own conclusion, as required by regulation.

Optionally, CEFEX can arrange for a legal opinion letter be issued to the plan effectively stating that the plan has met its regulatory obligation.

Review of Participant Disclosures

This review is focussed on the disclosures provided to participants of participant-directed retirement plans. It verifies 3 types of fee and performance disclosure information: general, administrative and investment-related.

Compliance with regulation - ERISA plans

DOL Regulation §2550.408b-2(c) requires 401(k) plan service providers to supply disclosures that

describe their services, plan-related expenses and fees, and their fiduciary status and requires plan fiduciaries to verify that service provider arrangements are reasonable.

DOL Regulation §2550.404a-5, requires plans to provide plan participants with detailed disclosures of their investment fees and administrative expenses.


The main benefit of a CEFEX Service Provider Disclosure Review (SPDR) is financial. Normally, a plan sponsor must perform its own due diligence in the selection of service providers, which is typically accomplished by conducting a Request for Proposal (RFP) process every three years. The RFP process can be expensive, in that a consultant is typically used, and/or it requires significant plan sponsor time and resources. It may also be unnecessarily disruptive to existing service provider relationships.

The SPDR is cost effective because it uses a consistent methodology and documents conclusions without time-consuming analysis. It leverages the expertise of an independent expert to analyse existing service providers.

There is no need to:

  • prepare RFP information
  • hire and inform a consultant to refine and issue the RFP
  • analyse multiple service provider responses
  • disrupt existing service provider relationships

The main benefit of a Participant Disclosure Review (PDR) is risk mitigation. It is your legal responsibility to ensure participant disclosures are appropriately delivered. If you fail to do this, you may face fines or penalties and put at risk relief from fiduciary liability afforded by ERISA §404(c). If you have outsourced this function to a service provider, are you certain the providers are fulfilling the function properly?

Order a CEFEX Participant Disclosure Review to rest assured.

How to order

Please contact us to arrange a discussion with one of our Analysts.