Important Deadlines for ERISA Plans to Receive and Report Information on Fees, Expenses

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Coming up this summer are a number of reporting and disclosure deadlines under the Employee Retirement Income Security Act of 1974 (ERISA) that deal with fees and expenses paid by plans that are subject to ERISA. Service providers to such plans, including investment managers who manage plan assets, and other entities that provide investment products (such as annuity contracts or collective investment funds), should be aware of their responsibilities and be prepared for requests for information from their ERISA plan clients.

July 1 is the deadline for "covered service providers" to provide plan fiduciaries with disclosure of the direct and indirect compensation they receive in connection with the services they provide to the plan, as required by regulations under Section 408(b)(2) of ERISA. Plan fiduciaries must use this information to determine whether the service provider arrangement is a "reasonable contract or arrangement" as required by ERISA...

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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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