DOL Proposes Extension of Applicability Dates for Plan Fee Disclosure Rules


The Department of Labor ("DOL") has issued proposed regulations that would extend and align the applicability dates for the interim-final rule regarding fiduciary-level fee disclosures under ERISA Section 408(b)(2) and the final rule regarding participant-level fee disclosures under ERISA Section 404(a).

On July 16, 2010, the DOL published interim-final regulations under ERISA Section 408(b)(2) requiring retirement plan service providers to disclose comprehensive information about their fees and potential conflicts of interest to plan fiduciaries. These disclosure requirements are scheduled to apply to service contracts or arrangements in existence on or after July 16, 2011; however, the DOL announced in February of this year that it intended to extend the applicability date to January 1, 2012. The proposal, when finalized, officially extends the applicability date.

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