Thank you for your question. I look forward to working with you to provide you the information you are seeking.
It is exactly that clause in Chapter 140 regarding prohibited activities that prohibits fee splitting or sharing with employer clients and thus charging the employer client and the employee both fees for service you are providing that substantiates what the DOL is telling you. MA DOL does not play games with this either as they take it very seriously and if they discover from an employee complaint or audit that you are violating this, they can come after you not only for reimbursement of the money you collected, but penalties and fines as well which can amount to 2-3 times the money you collected.
I would however be happy to review the document if you can upload it to http://www.wikisend.com for me to review.
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