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.

LOADING PDF: If there are any problems, click here to download the file.

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.

© Ropes & Gray LLP | Attorney Advertising

Written by:


Ropes & Gray LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.