Is anyone else having trouble with deciding what to ask (or even if I need to ask) 3rd party recordkeepers and investment funds about their compliance? DOL seems to require that inquiry.

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I agree the DOL indicates that this is an issue that you should address with the recordkeeper, trading platform, and systems software vendors. Many of the vendors have a standard statement available on their websites. So, you might want to check there first. If you cannot find anything basically, I believe you should ask them to provide a statement indicating what they have done to address the issue of handling year 2000 dates in their software programs. I believe that as long as you have a signed statement indicating that the vendor has taken addressed the Y2K issues, then you should be ok.

I don't think there's an expectation that you have to ask specific questions...I think that would be difficult since you don't know all the date fields designed into the systems.

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Carol J. Ringwald
Senior Consultant
Shawmut Consulting Assoc.