On March 2nd, the DOL issued final regulations implementing Section 101(k) of ERISA, which requires multiemployer plans (i.e., so-called "Taft-Hartley" plans, which are collectively bargained plans jointly administered by unions and employers) to furnish certain plan-related documents, including reports from investment advisers, upon the written request of plan participants or the participating unions or employers. Investment advisers with multiemployer plan clients may be affected by the regulations because reports and other communications to the plan are required to be disclosed upon request unless those documents fall within the exception for "proprietary information." The plan administrator is responsible for determining if a requested document constitutes "proprietary information," which is defined in the regulations as "trade secrets and other non-public information (e.g., processes, procedures, formulas, methodologies, techniques, strategies) that, if disclosed by the plan, may cause, or increase a reasonable risk of, financial harm to the plan, a contributing employer, or entity providing services to the plan." The regulations become effective April 1, 2010. Final Regulations.