Good news: As we noted in our September alert about the service provider fee disclosure regulations, in July the Department of Labor extended the deadlines for complying with the new retirement plan fee disclosure regulations.

Bad news: With the extended deadlines just around the corner, plan sponsors should begin now working with plan service providers and advisors to prepare for the considerable amount of information required to be provided in the disclosures.

May 31, 2012 Deadline to Begin Fee Disclosures to Participants The participant fee disclosure regulations require ERISA individual account plans (401(k), 403(b), etc.) with participant-directed investments to provide two types of disclosures to plan participants and beneficiaries: (1) an annual disclosure of specific plan and investment information, and (2) a quarterly disclosure of investment information and fees actually charged to participant accounts. For calendar year plans the initial annual disclosure must be provided no later than May 31, 2012. Thereafter, the plan must provide this annual disclosure information on or before the date new participants can first direct their investments and to all participants at least once every twelve months. In addition, participants and beneficiaries must receive quarterly disclosure statements at least once every three months. For calendar year plans the initial quarterly statement must be provided no later than August 14, 2012 covering the second quarter of 2012.