Los Angeles partner Fred Reish published an article in PlanSponsor, written with the assistance of Los Angeles partner Bruce Ashton and Chicago associate Joshua Waldbeser. The article, titled, “Gifts From Providers: Committee members must abide by certain rules,” discussed the issue of plan committee members receiving gifts from service providers, which the Department of Labor said can lead to fiduciary violations, prohibited transactions, or worse.
The authors suggest that plan committees adopt a formal policy before accepting gifts, keeping in mind that the policy should:
- Prohibit members from accepting gifts above $250;
- Provide an approval mechanism for expense reimbursement;
- Have a reporting procedure for violations; and
- Keep records of all gifts for at least six years.