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DOL Proposal Would Require New 'Roadmap' Guide for 408(b)(2) Fee Disclosures
The Wagner Law Group [Guidance Overview] Mar. 17, 2014
"The Guide requirement may require a substantial re-engineering of the ERISA 408(b)(2) disclosure process for affected firms. Even though the effective date is presumably many months away, the time and expense necessary to reconfigure a firm's disclosure process and to make the necessary technology changes may be significant, especially for larger firms with multiple offices and investment products. A decision will need to be made in the relatively near future as to whether Fee Disclosures as modified by the proposed Guide requirement should be handled through internal staffing and resources, or outsourced to a third party provider that is capable of preparing the required Fee Disclosures for a fee ."
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