As discussed in a previous alert, the Department of Labor (DOL) issued new rules that will require certain types of ERISA retirement plan service providers to disclose new fee information directly to plans. Since our last alert, there have been a few developments on these new rules.

First, the DOL extended the deadline for compliance with these rules. Covered service providers must now provide the required disclosures no later than April 1, 2012. While it is not clear what form the disclosures will take, some service providers have begun creating template disclosures in anticipation of the approaching deadline. Plan fiduciaries should therefore expect to receive some form of disclosure in the upcoming months. The DOL’s regulations are currently in interim final form, and final regulations are expected in the next few weeks. Although the final regulations are not expected to contain any significant substantive changes, it is possible that the effective date for compliance could be extended.