CPFA LICENSE COMPREHENSIVE SCRIPT 2026
QUESTIONS AND SOLUTIONS
◉ As the advisor, you can assist the plan sponsor by. Answer: by
asking about documents he or she may be missing from the fiduciary
file.
For example:
Are there any plan amendments?
Does he or she have copies of the required participant notices
(including participant fee disclosure) and account statements?
Where are the 408(b)(2) fee disclosure notices?
Does he or she have evidence that looked at the fee disclosure to
determine if plan fees are reasonable?
◉ You can also assist the plan sponsor in identifying the. Answer:
plan service providers who may have copies of these documents,
and assist him in setting up a fiduciary file.
◉ You may also want to show the sponsor a. Answer: sample DOL
investigation letter, so he is aware of what the DOL might ask in
advance of an investigation. You can point out that unsigned
documents or amendments and/or missing and incomplete plan
documentation may put him at risk in an audit.
,◉ You should assure the that Plan Sponsor is aware of. Answer: both
your role as an investment fiduciary regulations and what
documentation she may need to review based on specific financial
institution requirements.
◉ The advisor or the CPA is not responsible for. Answer: the
required plan amendments. The TPA or ERISA counsel can prepare
the required amendment.
◉ The plan docs need to be amended when. Answer: there is a law
change that impacts the plan, or when the fiduciaries are changing
the plan provisions.
◉ It is the fiduciaries' responsibility to. Answer: distribute fee
disclosures notices, the record keeper is the one who prepares them.
◉ The plan document, IPS, and SPD are only required to be updated
if. Answer: changes have been made by the plan fiduciaries or law
changes require a plan amendment and changes to the SPD.
◉ Fiduciaries have personal liability for. Answer: a "breach" of their
duties.
◉ It is important to remind the fiduciaries that an investment
involving a party in interest is prohibited even if. Answer: it has been
, beneficial to the plan participants and beneficiaries. The prohibited
transaction still must be corrected.
◉ Correcting prohibited transactions may or may not be done
through. Answer: the DOL Voluntary Fiduciary Corrections Program
(VFCP). Regardless, it is not the advisor's role to correct prohibited
transactions. Fiduciaries should consult an ERISA attorney to
identified prohibited transactions and assist in correcting the
transactions. Transactions should be corrected as soon as possible to
avoid additional taxation.
◉ Non-traditional plan investments can be associated with. Answer:
prohibited transactions
◉ It is a best practice to recommend that an ERISA attorney review.
Answer: non-traditional plan investments to identify potential
prohibited transactions.
◉ Spouses and lineal relatives of plan fiduciaries, such as children,
are. Answer: parties in interest
◉ Service providers to the plan, such as CPAs doing audits, ERISA
counsel, and plan advisors are also. Answer: parties in interest
QUESTIONS AND SOLUTIONS
◉ As the advisor, you can assist the plan sponsor by. Answer: by
asking about documents he or she may be missing from the fiduciary
file.
For example:
Are there any plan amendments?
Does he or she have copies of the required participant notices
(including participant fee disclosure) and account statements?
Where are the 408(b)(2) fee disclosure notices?
Does he or she have evidence that looked at the fee disclosure to
determine if plan fees are reasonable?
◉ You can also assist the plan sponsor in identifying the. Answer:
plan service providers who may have copies of these documents,
and assist him in setting up a fiduciary file.
◉ You may also want to show the sponsor a. Answer: sample DOL
investigation letter, so he is aware of what the DOL might ask in
advance of an investigation. You can point out that unsigned
documents or amendments and/or missing and incomplete plan
documentation may put him at risk in an audit.
,◉ You should assure the that Plan Sponsor is aware of. Answer: both
your role as an investment fiduciary regulations and what
documentation she may need to review based on specific financial
institution requirements.
◉ The advisor or the CPA is not responsible for. Answer: the
required plan amendments. The TPA or ERISA counsel can prepare
the required amendment.
◉ The plan docs need to be amended when. Answer: there is a law
change that impacts the plan, or when the fiduciaries are changing
the plan provisions.
◉ It is the fiduciaries' responsibility to. Answer: distribute fee
disclosures notices, the record keeper is the one who prepares them.
◉ The plan document, IPS, and SPD are only required to be updated
if. Answer: changes have been made by the plan fiduciaries or law
changes require a plan amendment and changes to the SPD.
◉ Fiduciaries have personal liability for. Answer: a "breach" of their
duties.
◉ It is important to remind the fiduciaries that an investment
involving a party in interest is prohibited even if. Answer: it has been
, beneficial to the plan participants and beneficiaries. The prohibited
transaction still must be corrected.
◉ Correcting prohibited transactions may or may not be done
through. Answer: the DOL Voluntary Fiduciary Corrections Program
(VFCP). Regardless, it is not the advisor's role to correct prohibited
transactions. Fiduciaries should consult an ERISA attorney to
identified prohibited transactions and assist in correcting the
transactions. Transactions should be corrected as soon as possible to
avoid additional taxation.
◉ Non-traditional plan investments can be associated with. Answer:
prohibited transactions
◉ It is a best practice to recommend that an ERISA attorney review.
Answer: non-traditional plan investments to identify potential
prohibited transactions.
◉ Spouses and lineal relatives of plan fiduciaries, such as children,
are. Answer: parties in interest
◉ Service providers to the plan, such as CPAs doing audits, ERISA
counsel, and plan advisors are also. Answer: parties in interest
