Therefore, employers should recognise the risk of ERISA liability and assess their turnover participation agreements accordingly. == The Ministry of Labour (“DOL”) has issued some opinions on participation in turnover. Since 1997, the DOL has taken the position that planners are required to fully insindinate on the amount and source of all supplier compensation, regardless of where it is drawn, including revenue equity payments. DOL Advisory Opinion 1997-16A. In 2012, Congress finally gave the planned a valuable tool for monitoring supplier fees in the form of the new ERISA Sec. 408 (b) (2) Royalty Opening Requirements. ERISA Fiduciary Administrators LLC (“EFA”) uses the data collected in these disclosures to monitor the adequacy of the provider`s compensation and determine the amount, source and purpose of all revenue equity payments. . .