What is an example of fees that are required to be broken out regardless of whether they are part of a bundle?
The Schedule C instructions include a general rule that, in the case of bundled service arrangements, revenue sharing within the bundled group generally does not need to be separately reported, with two exceptions. The first exception is that any person in the bundle receiving separate fees charged against a plan’s investment (e.g., investment management fees, float revenue, and other asset-based fees, such as shareholder servicing fees, 12b-1 fees, and wrap fees if charged in addition to the investment management fee) must be treated as receiving separately reportable compensation for Schedule C purposes. Examples of separate fees charged against a plans investment for purposes of this exception are revenue sharing payments for shareholder services, recordkeeping or compliance services that are paid by an investment provider to a third party administrator (“TPA”) if they are charged against the plans investment as a separate amount or pursuant to a separate formula. Thus, if the inves
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