UPDATE: Fee Disclosure Rules for Defined Contribution Plans: Deadlines Extended for Disclosures to Plan Participants & New Obligations on Plan Sponsors under Service Provider Regulations

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At the end of 2011, we alerted you to final regulations (the "Final Regulations") by the U.S. Department of Labor ("DOL") that would apply as early as May 31, 2012 requiring plan administrators of participant-directed defined contribution retirement plans that are covered by the Employee Retirement Income Security Act ("ERISA") to disclose certain plan and investment-related information, including fee, expense and investment performance information, to participants and beneficiaries. (For background and more detailed information regarding the Final Regulations, see our previous Alert located at http://www.pbwt.com/2012-new-disclosures-to-defined-contribution plan-participants/) The DOL has now taken action that extends the deadlines associated with the Final Regulations by three months. The impact of this extension on the specific notices under the Final Regulations are as follows...

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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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