Legal Alerts

Department of Labor Extends Applicability Date for Retirement Plan Fee Disclosure Rules

07.01.11

The United States Department of Labor (“DOL”) has issued final rules extending the applicability date for retirement plan fee disclosures until at least April 1, 2012.  These rules require both fiduciary fee disclosure and participant fee disclosure. 

The fiduciary fee disclosure rules require service providers (mutual fund managers, record-keepers, etc.) to disclose information to assist employers in understanding the reasonableness of the fees being charged for plan services and to assess potential conflicts of interests that might affect the quality of those services.  These rules were originally scheduled to apply to all contracts or arrangements in existence on or after July 16, 2011.  The rules were subsequently delayed until January 1, 2012, and are now delayed until April 1, 2012.  The DOL commented that it intends to publish final fee disclosure regulations before the end of the year, and does not expect the changes to the rules will require any further extension of the applicability date. 

The participant fee disclosure rules require plan administrators to disclose plan fee and expense information to plan participants and beneficiaries.  These rules were originally scheduled to apply for the first plan year on or after November 1, 2011.  The rules are now delayed until the later of (i) 60 days after the first plan year beginning after November 1, 2011, and (ii) 60 days after the effective date of the fee disclosure regulations (April 1, 2012).  For a calendar year plan, this means the initial annual disclosure must be provided by May 31, 2012.

Contact
LaFromboise, Antoine J.
Communications and Brand Manager
T 612.371.3269

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