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Fiduciaries, Are You Ready for Rules Requiring Investment and Fee Disclosures to Participants?
Chang, Ruthenberg & Long 
[Guidance Overview] Apr. 2, 2012
"If your plan is being operated as an ERISA section 404(c) plan, such that the plan's fiduciaries are not intended to be responsible for the consequences of participants' investment directions, you must comply with these new rules or run the risk of losing your 404(c) protection."
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