The U.S. Department of Labor (“DOL”) published final regulations on February 3, 2012 (the “Regulation”) regarding the disclosure obligations that service providers to covered plans must satisfy in order for an arrangement to be reasonable and therefore to qualify for the exemption for service contracts or arrange-ments between a plan and a party in interest under Section 408(b)(2) of ERISA (and the corresponding provisions of the Internal Revenue Code).

The Regulation’s effective date has been ex-tended by three months to July 1, 2012 (from April 1, 2012) to allow additional time for com-pliance. Therefore, covered service providers must now provide initial disclosures to covered plans prior to July 1, 2012.

The Regulation generally retains the basic structure and content of the interim final regulations and a summary of the Regulation, as now modified, is below. Notable changes to the Regulation include...

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