Status of Fee Disclosure Regs

[Laura Harrington]

I was on maternity leave from mid-January to a few weeks ago. While I tried to stay abreast of what was going on in the retirement plan arena, I have to admit that I was slightly pre-occupied with my darling daughter and probably missed a thing or two!

I want to confirm the status of the DOL's three-part fee disclosure initiative:

The proposed regulations for the participant-fee disclsoures under ERISA 404(a)(5) and the service provider disclosures under ERISA 408(b)(2) were not finalized and have been put on hold indefinitely.

Part III of the initiative, which affected the Schedule C attachment to the Form 5500, has been finalized. No changes have been made to the 1/1/2009 effective date or the scope of these rules in light of the new administration.

Did I miss anything?

Thank you!

Laura

[TPApril]

Well I feel naive posting this question, but I had thought that the final regs for 408(b)(2) had been published and we are now working towards putting them into effect by 1/1/12. I was recently told by attorneys that the final regs are not out yet. I did a quick search and found the Federal Register publication dated 7/16/10 entitled 'Interim Final Rule'. I was thinking a best practice would be to get started with these rules. As an industry are we on hold waiting for additional rules prior to 1/1/12 and we should wait before revising our contracts?