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The costs of operating a 401(k) plan are usually charged to participants either directly or indirectly. When a plan pays the cost of recordkeeping directly from plan assets, the payments are allocated to participants’ accounts either as a percent of their account balance (pro rata) or as a set dollar amount to each participant’s account (per capita). While the DOL says that the allocation of expenses is a fiduciary decision and must be done prudently, both pro rata and per capita allocations have been seen as acceptable.
The views expressed here are those of Fred Reish. They should not be construed as investment advice or as the views of Hartford Funds or the employees of Hartford Funds. They are based on available information and are subject to change without notice. The information above is intended as general information and is not intended to provide, nor may it be construed as providing, tax, accounting or legal advice. As with all matters of a tax or legal nature, please consult with your tax or legal counsel for advice. This material and/or its contents are current at the time of writing and may not be reproduced or distributed in whole or in part, for any purpose, without the express written consent of Fred Reish.
MFDC070 3149162
JD, Partner, Faegre Drinker Biddle & Reath LLP
Fred Reish is an ERISA attorney whose practice focuses on fiduciary responsibility, retirement income, and plan operational issues. He has been recognized as one of the “legends” of the retirement industry by both PLANADVISER magazine and PLANSPONSOR magazine.