Are you getting prepared for the required fee disclosures? The good news is that the DOL issued the final rule on the extension of the 408(b)(2) and participant-level disclosures applicability dates and extended it until April 1, 2012. Final regulations are due by the end of the year. Plans will have to make participant-level disclosures within 60-days after the effective date.
If you have not made yourself familiar with the fee disclosure rules under 408(b)(2), I suggest you take a look at two documents. The first is the ESBA Final Rules (published in July of 2010). The second is an Interim Fact Sheet that the DOL published as well. What is key to remember is that there are several ongoing fee disclosure requirements for plan sponsors. There are Disclosure of Services and Compensation requirements that service providers have to furnish to fiduciaries, and then there are also ongoing fiduciary obligations to report those fee disclosures back to participants.
So whether you are a plan sponsor or a plan service provider, get to know these new requirements. We have some time to prepare.