The effective dates of the new Department of Labor (“DOL”) regulations on service provider disclosures and investment fee disclosures for retirement plans are almost here. The service provider disclosure regulations-which require the plan administrator to collect service and fee information from the plan’s service provider-are effective July 1. The investment fee disclosures-which require the plan administrator to collect and distribute to participants performance and fee information on the plan’s designated investments-generally become effective on August 30. There could be severe consequences for failing to comply with these regulations, such as AUTOMATIC prohibited transactions for not complying with the service provider disclosure rules by July 1.
To help you deal with the new regulations, I make available two documents- my article “The New Service Provider and Participant Fee Disclosure Rules-What They Are, When They Apply and How to Prepare for Them”, which appeared in the BNA Pension & Daily (May 21, 2012) and a Summary of the Rules. The Summary is intended to let you know what is involved. If you are the plan administrator of a retirement plan, or have any responsibility to one, you really need to look at these docs. If you want copies and /or have any questions,please contact me through the blog, call me (516-307-1550) or email me (firstname.lastname@example.org).