What the CAA Now Requires Brokers to Disclose About Their Fees, With AJ Loiacono. Why 2022 Is a "Magical Moment" for Plan Sponsors to Demand Broker Fee Disclosure. Episode 379. Stacey Richter talks with AJ Loiacono, CEO of Capital Rx, about how the Consolidated Appropriations Act now requires employee benefit consultants and brokers to disclose all the money they make off a plan sponsor—direct and indirect—and what happens when they don't comply. WHAT YOU'LL LEARN ✅ Why the CAA, in effect since December 2021, requires brokers, EBCs, TPAs, and PBMs to disclose all compensation they receive from a plan sponsor, not just direct fees ✅ Real examples of hidden per-script compensation arrangements, including quarterly payments routed to a PO box in another state ✅ Why plan sponsors, as ERISA fiduciaries, are legally responsible for determining whether these disclosed fees are reasonable and free from conflict ✅ The concrete steps a plan sponsor should take: request disclosure in writing, in actual dollars rather than percentages, then report noncompliance to the Department of Labor ✅ Why public reporting of one broker's noncompliance creates real legal exposure for every other plan sponsor still using that same broker ✅ Why Loiacono calls 2022 a "magical moment" for plan sponsors and above-board EBCs alike, given how directly the CAA now enables this kind of scrutiny WHY THIS MATTERS Hidden compensation arrangements between brokers, TPAs, and PBMs directly inflate what plan sponsors and employees pay, and the CAA gives plan sponsors real legal leverage to demand transparency they couldn't previously compel. Loiacono's breakdown turns a dense regulatory requirement into a concrete action plan any self-insured employer can follow starting now. === LINKS === 🔗 Show Notes with all mentioned links: Episode Page ✉️ Enjoy this podcast? Subscribe to the free weekly newsletter 🫙 Support the podcast with a small donation to the Tip Jar 📺 Subscribe to our YouTube channel 🎤 Listen on Apple Podcasts 🎤 Listen on Spotify === CONNECT WITH THE RHV TEAM === ✭ LinkedIn ✭ Threads ✭ Bluesky ✭ X 06:03 Who can get in trouble for mismanaging employee funds? 06:31 Who can begin the cycle for annual review? 07:53 "When you talk about conflicts of interest, they're everywhere." 13:17 "You're paying for access." 13:38 Why is it important to request that they disclose direct and indirect compensation? 14:08 What are the layers to these hidden fees and compensations? 18:17 What is a reasonable fee for a good plan admin? 19:32 "I think people need to step back and say, 'How many different ways are they getting compensated?'" 24:57 "The compensation is not just unreasonable, but if they were to move it, they would lose access to an entire column of revenue." 25:13 "For every good broker consultant, there's a horrible individual lurking out there and it's easy to figure out: Ask for them to disclose their fees." 28:14 "You can't win if you can't even pay the house fee to come in." 31:42 Why do you need to ask for disclosure, and what do you need to ask specifically? 32:27 What are some of the characteristics of a good plan consultant?