The Department of Labor has extended the effective dates of the fiduciary-level fee disclosure requirements under ERISA § 408(b)(2) (See August 2010 Benefits Insights)and the participant-level fee disclosure requirements under ERISA § 404(a) (See March 2011 Benefits Insights).

The final regulations delay the fiduciary-level fee disclosure to April 1, 2012.  The initial participant-level fee disclosure must be furnished to participants no later than May 31, 2012 for calendar year plans.  The quarterly participant-level fee disclosure must be furnished no later than August 14, 2012 for calendar year plans.