I would be very interested in feedback from TPA's re recent DOL investigations. Thanks for any input about your experiences.

We have a former client that is currently being investigated by the DOL. The plan trustees were married to each other and the divorce must have been nasty. Each is uncooperative with the other. The auditor has been very amiable and helpful, in spite of the fact that one of the trustees has ignored a DOL subpeona for records. The auditor's primary concern has been getting the plan terminated and participant's their benefit.

I am not sure what the origin of your question is, but I just had a TPA client call about a soon to be received subpoena from the DOL regarding any knowledge of violations by its clients of the 15th business day trust deposit rules for 401(k) deferrals. The PWBA investigator informed me that this is some sort of random new initiative from the department. I haven't yet seen the subpoena, so I don't know yet what the TPA is being asked to do.