It's important to maintain strong relationships with employee benefit advisers who provide professional services at reasonable fees. However, employers must periodically question why they maintain certain relationships, particularly if fees appear to be higher than usual and/or service has declined. Sometimes a relationship is maintained with a vendor due to a long-term friendship. Other times it's maintained due to the influence of a parent corporation or for other business reasons. In all circumstances, employers should periodically evaluate vendors, fees and services, and ensure that no undue influences exist. For this reason, many employers should consider establishing a formal ERISA fiduciary gift policy.

In the union environment, establishing gift policies and reporting gifts have existed for many years. Under the Labor Management Reporting and Disclosure Act of 1959, union officers, employees and representatives are required to file a Form LM-30, Labor Organization Officer and Employee Report, disclosing certain payments received from parties dealing with the union or an affiliated employee benefit plan. Employers, including service providers to Taft-Hartley Plans, must also file a Form LM-10, Employer Report, disclosing any items of value given to a labor organization, union official, employee or labor relations consultant.

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