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DOL Revises Guidance on Participant Fee Disclosures for Brokerage Window Investments
McDermott Will & Emery Link to more items from this source
[Guidance Overview]
Aug. 7, 2012
"Q&A-39 is welcome guidance for fiduciaries of plans with [Self-Directed Brokerage Arrangements (SDBAs)] ... Fiduciaries are still bound by the general ERISA fiduciary duties of prudence and loyalty to participants who use SDBAs, including taking into account the nature and quality of services provided in connection with the SDBA. The DOL also noted that while plans are not required to have a particular number of designated investment alternatives, the failure to designate any investment alternatives (for example, to avoid fee disclosure obligations) would raise questions under the general fiduciary duties of prudence and loyalty."

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