Preparing for participant-level fee disclosures

HRS Insight
On October 20, 2010, the U.S. Department of Labor (the "DOL") released a new regulation requiring ERISA plan sponsors to provide for more comprehensive participant-level fee disclosures. The regulation is intended to ensure that all participants and beneficiaries in ERISA-directed individual account plans have the information needed to make informed decisions about their investment choices. Although the regulation applies to plans for plan years beginning on or after November 1, 2011 (January 1, 2012 for calendar year plans), the DOL issued a revised transition rule, which has delayed the initial compliance date for calendar year plans to May 31, 2012. Although there is speculation that this deadline will be extended further, it is imperative that plan recordkeepers and providers associated with plans' investment options take steps now to assist plan sponsors in complying with these new disclosure requirements. Although the party responsible for complying with the new DOL Regulation is plan sponsors, plan recordkeepers and financial institutions associated with plans' investment options should be prepared to provide assistance so that the required information is available for plan sponsors to satisfy the disclosure requirements mandated by the DOL Regulation.

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