Fee disclosure extension

[austin3515]

http://www.dol.gov/ebsa/regs/fab2013-2.html

Fee disclosures due date extended to "18 months" for this year to allow plan sponsors to "reset" the filing deadline to coordinate with SH Notices, for example.

[Jim Chad]

The DOL says this is just for the investment chart. Are people treating this as being for the whole 404(a) disclosure?

[John Feldt ERPA CPC QPA]

Craig Hoffman pointed out yesterday that the relief leaves out c2 and c3, which are the disclosures required for potential plan-wide recordkeeping or annual plan administration fees (c2) and the potential inidividual fees that might be charged like distribution fees, loan fees, QDRO review, etc. (c3).

So, the relief is either A) meaningless because the disclosures must be all provided together (remember, you can't use separate envelopes to disclose those fees without the invest fee disclosures and the comparative chart also being in that envelope), or B) the relief means everything other than the fees under c2 and c3 can be disclosed later and the DOL has now unlinked those fees from having to be disclosed in the same notice as the investment fees.

Edit: due to a breaking news update: The DOL fixed this today, and I believe all of the disclosure pieces are now included.

[lalaland]

John, can you share where the DOL fix is?

[John Feldt ERPA CPC QPA]

See attached, it now references all of c with d1 and d2 (3rd page, first full paragraph).

fab2013-2.v2.pdf