Effective Date Deferred until 2012 for New ERISA Regulations on Fee Disclosure


The Department of Labor announced on February 11 that new rules regarding fee disclosure by providers of services to ERISA plans will not take effect until January 1, 2012. As we informed you in a prior Alert, new rules released on July 16, 2010 as interim final regulations had been scheduled to go into effect on July 16, 2011.

As outlined in our prior Alert, the Department’s interim final regulations under Section 408(b)(2) of ERISA would require detailed disclosure of direct and indirect fees paid for services provided to ERISA plans, including the estimated cost of recordkeeping services for which no explicit compensation is paid.

Please see full alert below for more information.

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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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