DOL Sets Final Effective Dates for ERISA Fee Disclosure Rules


The Department of Labor has issued a final rule that extends the effective dates of the new fee disclosure rules for ERISA plans.

• The effective date for the rules requiring service providers to disclose fee information to plan fiduciaries has been extended from July 16, 2011 to April 1, 2012. The new effective date is three months later than the extended effective date that was proposed in a notice published on May 31, 2011 (discussed in our Alert of June 1, 2011).

• The deadline for plan administrators to furnish certain detailed fee disclosures to participants in participant-directed 401(k) and other plans has been pushed back to 60 days after the new service provider fee disclosure rules take effect – that is, to May 31, 2012, assuming no further extensions of the April 1, 2012 effective date – or, if later, 60 days after the first day of the first plan year that begins on or after November 1, 2011. Quarterly disclosures required under the new rules will need to be furnished to participants and beneficiaries no later than 45 days after the end of the quarter in which the initial fee disclosures are furnished.

The Department’s decision comes as a response to comments on its May 31, 2011 notice, many of which stated that additional time is needed to comply with the new disclosure rules. The Department stated that extending the effective dates as described above strikes a balance between providing additional time needed for effective compliance and timely implementation of the new rules.

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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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