Does the 404(c) rule require anything that the new 404(a) rule doesn't require?

[Peter Gulia]

For plan years that begin on or after November 1, 2011, the administrator and other fiduciaries of an individual-account retirement plan that provides participant-directed investment must see to it that participants (and those beneficiaries and alternate payees who are directing persons) are furnished sufficient information for them to make informed decisions.

This disclosure is required (under an interpretation of fiduciary duties under ERISA 404(a)) even if none of the fiduciaries wants the protection of ERISA 404©.

What are the essential differences (if any) in the disclosures required under these two rules?

Is there ary disclosure required for protection under the 404© rule that is not required under the 404(a) rule?