When is the Broker & Consultant Compensation Disclosure due?

Reasonably in advance of entering into or renewing a service contract or arrangement. Our recommended target, not a legal deadline for every plan: 60 days before the renewal effective date, so you have it before you sign.

Who is responsible for the Broker & Consultant Compensation Disclosure?

Broker. Delivered to: Responsible plan fiduciary (employer/plan sponsor).

Compliance Calendar/Resource

Notice & DisclosureAnnual

Broker & Consultant Compensation Disclosure

CAA 2021 § 202; ERISA § 408(b)(2)(B)

Brokers, consultants, and other service providers to group health plans must disclose all direct and indirect compensation expected to be received for services. Includes commissions, fees, bonuses, overrides, and any other compensation. Disclosure must be made to the responsible plan fiduciary.

ResponsibleBroker

Deliver ToResponsible plan fiduciary (employer/plan sponsor)

Legal timingReasonably in advance of entering into or renewing a service contract or arrangement

Our target60 days before the renewal effective date, so you have it before you sign. This is our recommended timing, not a legal deadline for every plan. The legal timing is above.

Broker & Consultant Compensation Disclosure

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