408(b)(2):                                                                                                                       The disclosure in itself is just the tip of the iceberg.  The purpose of this disclosure is for Plan Sponsors to have all the information necessary to determine the reasonableness of that compensation.  In other words, was the amount paid by the plan to the Service Provider an appropriate amount, based on the services rendered, time spent, and experience and credentials of the Service Provider? 

The inherent problem can be expressed very simply: what is reasonable?  In our opinion, reasonableness of fees paid and services rendered can be best assessed using benchmarking.  In other words, what are similar plans paying for similar services, provided by a similarly credentialed professional? 

We have created a reporting system which benchmarks the Plan in question against other similar plans (similar asset size and number of participants).  This system provides real data with which Plan Sponsors can assess the reasonableness of fees paid to its Service Providers, taking into consideration the scope of services rendered by those Service Providers.