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Deadline Finally Set for New 408(b)(2) Fee Disclosure Rule Compliance
Chang, Ruthenberg & Long 
[Guidance Overview] Feb. 7, 2012
[What To Do After The Deadline.] Be sure to: Go through the process again for each new arrangement, for any extension or renewal of an existing arrangement, and for any changes; If a disclosure failure is discovered, follow the steps in the prohibited transaction exemption that is part of the final regulations, to include notifying the DOL if appropriate, reporting the failure on Form 5500, and deciding whether to terminate the arrangement with the covered service provider.
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