I have heard stories about providers who were penalized by the DOL because they took too long to transfer plan assets to a new provider, once sufficient (in whose eyes?) instruction had been received.

Does anyone have any direct experience with such activity? The principals of our company sometimes delay the transfer for a period of time while they try to "save" the case, and while I know there may be fiduciary exposure in theory, I would like some anecdotal reports if there are any.

The NSCC has established timeframes within which Automated Customer Account Transfers (ACAT) must be completed, and may impose a fine on the member organization that fails to comply with these timeframes. The NSCC and its members determine what is “sufficient” instructions, which are subject to further approval by the Settling member


I am not aware of any such DOL requirements…not to imply there are none…