The IRS requires the district or employer to provide all eligible participants with an annual notice or information about the 403(b) plan (this is part of the universal availability rule). This is to encourage participants to save through the program. California Education Code Section 44041.5 requires TPAs to disclose any fees, commissions, cost offsets, reimbursements or marketing or promotional items received by vendors. We were suggesting that if your district uses a TPA, it should disclose this information at the time it complies with the IRS annual notice requirement (universal availability).