"We're not against people getting paid, but it needs to be reasonable and fully disclosed," he says. If a broker makes $50,000 on a plan and only comes twice a year to provide education, that's not reasonable, he says.

More best practices Millenium shares are having all service providers (not brokers) complete and sign the Labor Department's fee disclosure form and reviewing the Security & Exchange Commission's tips for plan fiduciaries (http://www.sec.gov/investor/pubs/sponsortips.htm).

Fiduciaries with good documentation are also more likely to be able to come through the Labor Department's Voluntary Fiduciary Correction Program (VFCP) with greater success.

Holland's big suggestion: Allow enough time to get onboard with compliance. "You're not going to be able to flip a switch and be ready," he says.
For a free copy of Millenium's worksheet, contact him at [email protected] or (704) 743-3226.

- Jerilyn Klein Bier

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