International Paper - PLANSPONSOR.com

Case 3:06-cv-00703-DRH-CJP Document 2 Filed 09/11/2006 Page 24 of 52B. By receiving, or having the opportunity to receive, “Revenue Sharing”payments comprised of the Plans assets distributed between and/or amongvarious service providers.“Hard Dollar” Payments to Plan Service Providers90. Payments in the form of direct disbursements from the Plans to individuals orentities providing services to the Plan are characterized as “Hard Dollar” payments.91. The Plans discloses to government regulators and Plan participants, in one formor another, Hard Dollar payments made from the Plans to service providers. For example, theSalaried Plan disclosed in filings with government regulators that in 2004 it paid: (A) $780,230to Towers Perrin and JP Morgan, the Salaried Plan’s recordkeepers; and (B) $394,873 toPriceWaterhouseCoopers and Deloitte & Touche LLP, the Salaried Plan’s auditors. Defendantsprovided no further detail regarding payments to Salaried Plan service providers in theirdisclosures to government regulators and Plan participants.92. Based upon these disclosures, understanding the Salaried Plan’s service providerexpenses for 2004 appears straightforward: The Salaried Plan sent checks totaling $1,175,103 toits recordkeepers and auditors and, in exchange, the Salaried Plan received the requiredrecordkeeping and auditing services for 2004.“Hard Dollar’ Expenses and Master Trusts93. When plans, such as IPC’s Salaried and Hourly Plans, are administered through amaster trust, the disclosure of Hard Dollar payments for services provided to a 401(k) plan maybecome incomplete, unclear, inaccurate and/or misleading.24