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A fiduciary is someone who has undertaken to act for or on behalf of another in a particular matter in circumstances which give rise to a relationship of trust and confidence.

-Bristol and West Building Society vs Mothew

We have been swamped with calls from Auditors all over the country “How can I help my clients with this Independent assessment?” “Am I obligated to do so?” How do I protect myself & the firm in the process?

MIRA led by our I.R.S. Enrolled Agents & CPAs have developed the P3 program ( Pay, Performance, Parity) & ERISA Due Diligence Review these programs are designed to ensure your client's plans are fully ERISA compliant.


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MillenniuM has expertise in providing the following services:

  • Fiduciary Risk Management
  • Retirement Plan Committee Organization
  • Investment Policy Statement Design and Implementation
  • Investment Selection and Monitoring
  • Fee Reviews and Benchmarking
  • Fiduciary Studies
  • Customized Participant Education Programs
  • Fiduciary Best Practices Updates
  • Vendor Search and Selection

Form 5500 and Schedule C

As you are probably aware, the new Form 5500 and Schedule C requires much more cost and fee disclosure as well as an affirmation that the plan has no “prohibited transactions”. According to the Department of Labor, “If the consultant is a fiduciary under ERISA and receives fees from third parties as a result of their recommendations, a prohibited transaction under ERISA occurs unless the fees are used for the benefit of the plan (e.g., offset against the consulting fees charged the plan) or there is a relevant exemption.” (See “Selecting And Monitoring Pension Consultants - Tips For Plan Fiduciaries”)

The updated 5500 was designed to work together with the new 408 (b)(2) regulations. As a result, some service providers may not make the disclosures which are necessary to accurately complete the updated Schedule C.