Delay in Fee Disclosure Effective Dates

Today, February 2, 2012, the US Department of Labor (DOL) and the Employee Benefits Security Administration (EBSA) issued the "Final Regulation Relating to Service Provider Disclosures Under Section 408(b)(2)". According to the final regulations, the effective date for participant-level disclosure is July 1, 2012 for both existing and new contracts or arrangements between covered plans and covered service providers... "Consequently, for calendar year plans, the initial annual disclosure of "plan-level" and "investment-level" information (including associated fees and expenses) must be furnished no later than August 30, 2012 (i.e., 60 days after the 408(b)(2) regulation's July 1 effective date).  The first quarterly statement must then be furnished no later than November 14, 2012 (ie., 45 days after the end of the third quarter (July through September), during which initial disclosure were first required)."
 
Click here to go to the DOL's website to read a fact sheet on the "Final Regulation Relating to Service Provider Disclosures Under Section 408(b)(2)."
 
Baden Retirement Plan Services has been preparing processes and information for its plan sponsor and financial advisor contacts to comply with the regulations.  Please contact us with questions about the new fee disclosure regulations.