DOL Further Defers Compliance Dates for New Disclosures

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In amendments to ERISA regulations released on July 13, 2011, the U.S. Department of Labor further extended the initial compliance dates for its new retirement plan service provider disclosure under §408(b)(2) and participant disclosure under §404(a), beyond the dates informally announced in February 2011 and proposed on June 1, 2011.

In response to comments about the compliance challenges presented by the new disclosure requirements and the wisdom of delivering the service provider disclosures to plan fiduciaries prior to the delivery of the new disclosures to participants, DOL reset:

- The effective date for the service provider disclosure to April 1, 2012;

- The date for the initial delivery of participant disclosures to 60 days after the later of: (1) April 1, 2012, or (2) the first day of the first plan year beginning on or after November 1, 2011; and

- The date for the delivery of the initial quarterly disclosure required under the participant disclosure regulation to 45 days after the end of the quarter in which the initial disclosure to participants is required.

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