Request a Proposal

Fee Disclosure for Model Portfolios

The DOL released a Field Assistance Bulletin to provide clarity around the application of fee disclosure rules for model portfolios – portfolios comprised of core investment options (designated investment alternatives) available to plan participants. The bulletin states that a model portfolio is not usually required to be treated as a designated investment alternative (DIA) under the disclosure rules if it is presented to the participants and plan beneficiaries as a way of allocating their retirement balances among the DIAs offered within the plan.

That said, however, there are two exceptions noted in which model portfolios would be treated as DIAs thus requiring disclosures. If a plan only offers model portfolios absent of any DIAs or the model portfolios include any investments not considered DIAs, then the model portfolio must be treated as a DIA for disclosure purposes.