On February 11, 2011, the Department of Labor (“DOL”) announced that it intended to delay the effective date of recently promulgated pension plan service provider fee disclosure rules until January 1, 2012. The previous compliance date was July 16, 2011 for service provider contracts or arrangements in effect on or before that date and for any contracts or arrangements entered into after that date. As previously reported in a July 29, 2010 advisory, the rules provide plan fiduciaries and service providers guidance on what constitutes a “reasonable” contract for plan services, and requires covered service providers to disclose specific information about the compensation and services to be performed. Covered service providers are those that enter into a contract or arrangement with a covered plan (i.e., a defined benefit or defined contribution plan) that reasonably expect to receive $1,000 or more in compensation, directly or indirectly, for services to plans such as fiduciary or investment advisory services, recordkeeping or brokerage services, or various other services. Responsible plan fiduciaries must carefully examine these disclosures to ensure that the contract and fees are appropriate for the plan.