Be More Than A Fiduciary

Chris Frank and Shannon Knapp: Float Income is a Plan Asset


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Chris Frank, a member of John Hancock’s Benefits Consulting Group, manages the DC Consulting Team and delivers fiduciary support services. With over 30 years of experience, he previously served as ERISA counsel. Chris holds degrees from the University of Massachusetts, Babson College, and the New England School of Law. Outside of work, he enjoys family time and vacationing in New Hampshire and Newport, RI.


Shannon, with over 20 years in financial services, manages sales and relationship development for John Hancock across several states. Since joining in 2012, he has expanded the client base by collaborating with advisors and consulting firms. He holds multiple financial designations and a B.S. in Finance from the University of Alabama. A former U.S. Army Cavalry Scout, Shannon enjoys running, college football, and his children's sports activities in Argyle, Texas.


In this episode, Eric, Chris, and Shannon discuss:

  • What is float income? 
  • Practicing proper disclosure of fees and compensation
  • Ensuring reasonable fees by addressing float income 
  • Reporting float income discussion and process in meeting minutes 


Key Takeaways:

  • Float income is compensation received by record keepers or trustees from temporarily investing cash held in accounts for planned transactions. Rising interest rates increase float income, which plans must monitor for reasonableness and proper handling.
  • Plan advisors should follow DOL guidelines, particularly FAB 2002-3, to ensure proper disclosure of fees and compensation, reducing risks of self-dealing and unreasonable fees. Float income is considered a plan asset by the DOL. 
  • Plan fiduciaries must understand and address float income arrangements to ensure plan fees are reasonable, regardless of plan size.
  • Plan committees should review float income policy, circumstances triggering such income, total compensation paid to providers including float income, and document discussions and findings regarding float income reasonably in meeting minutes.


“Your responsibility is to make sure all plan fees are reasonable, and then document all discussions and findings as it relates to float income. Put it in your meeting minutes.” - Chris Frank and Shannon Knapp


Connect with Chris Frank:

Email: [email protected] 


Connect with Shannon Knapp:

Email: [email protected]

Telephone: (940) 390-1046



Connect with Eric Dyson: 

Website: https://90northllc.com/

Phone: 940-248-4800

Email: [email protected] 

LinkedIn: https://www.linkedin.com/in/401kguy/ 



The information and content of this podcast is general in nature and is provided solely for educational and informational purposes. It is believed to be accurate and reliable as of the posting date but may be subject to change

It is not intended to provide a specific recommendation for any type of product or service discussed in this presentation or to provide any warranties, investment advice, financial advice, tax, plan design or legal advice (unless otherwise specifically indicated). Please consult your own independent advisor as to any investment, tax, or legal statements made.

The specific facts and circumstances of all qualified plans can vary and the information contained in this podcast may or may not apply to your individual circumstances or to your plan or client plan-specific circumstances.

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Be More Than A FiduciaryBy Eric Dyson

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