DOL Proposes Coordinated Effective Dates for ERISA Fee Disclosure Rules


On May 31, 2011, the Department of Labor issued a notice officially proposing to move the effective date of new fee disclosure rules for providers of services to retirement plans from July 16, 2011 to January 1, 2012 (previously discussed in our Alert of February 14, 2011). The notice also proposes to allow 120 days (rather than 60 days) after the applicability date for plan administrators to provide certain detailed fee disclosures to participants in participant-directed 401(k) and other plans, under related rules that are generally applicable for plan years beginning on or after November 1, 2011.

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