July 1 is the deadline by which certain providers of services to ERISA-covered retirement plans must provide fee and other information to these plans under a new Department of Labor (DOL) disclosure requirement. The disclosure is necessary to the extent that the service provider, its affiliates or its subcontractors are compensated from assets of the plan.
If a covered service provider under an existing services arrangement with a plan does not comply with the disclosure requirement by July 1, the plan fiduciary responsible for hiring and monitoring that service provider must take specific actions, which may include notifying the DOL of the noncompliance and/or terminating the services arrangement.
For further information, please see our earlier article, A Plan Fiduciary’s Guide to the Service Provider Disclosure Rules. In addition, the DOL has released some limited guidance concerning these rules in Field Assistance Bulletin No. 2012-02 and has indicated that more guidance will be published before the July 1 deadline.