"Eighty percent of retirement plans operate on a calendar-year basis.... [B]ecause many participant fee disclosures are due in August, plans cannot combine them with the disclosures that are sent out in September or even later in the year. As a result, plans will incur considerable additional expense to mail these disclosures separately from their other disclosures -- and with little or no benefit to participants.... ERIC recommends the Department issue guidance that interprets the regulation's definition of 'at least annually thereafter' to mean at least once in any twelve-month period, but no later than 18 months from the last annual disclosure."

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