Fee disclosures can be improved

Ary Rosenbaum - The Rosenbaum Law Firm P.C.
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Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The fee disclosure regulations were one of the best things that ever happened to the retirement plan business. Yet, what is great, can be improved.

Sections 340 and 341 of Secure 2.0 request that the Department of Labor (DOL) and the Internal Revenue Service (IRS) to review defined contribution plan fee disclosures and plan notices provided to participants, giving Congress three years to amend fee disclosure rules and two years to consolidate required plan notices. The DOL requested public feedback on these sections and other provisions of SECURE 2.0 on August 11.

I still think the DOL dropped the ball, by not requiring model notices or standardized language. Like food labels, a standardized format would make it easier for plan sponsors, participants, and other plan providers.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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