Employee Benefits - Two Weeks to Go: Retirement Plan Fiduciaries, Are You Prepared for the New ERISA 408(b)(2) Service Provider Disclosures?

June 15, 2012

In this issue:

Two Weeks to Go: Retirement Plan Fiduciaries, Are You Prepared for the New ERISA 408(b)(2) Service Provider Disclosures?

It is just shy of two weeks until July 1, 2012, the deadline by which all covered service providers to qualified retirement plans and 403(b) plans subject to ERISA must provide the fee and service related disclosures under the new Department of Labor ("DOL") regulations under ERISA 408(b)(2). If you are a fiduciary to a covered retirement plan that has the authority to cause the plan to enter into, extend or renew a service provider's contract, you are what is known as a "responsible fiduciary." As though there are not enough duties you have to perform as an ERISA fiduciary, ERISA 408(b)(2) adds a few more and adds some urgency to fulfilling your existing duties related to service contracts and fees. This Client Alert reviews the 408(b)(2) disclosure requirements and provides you as a responsible fiduciary recommendations on actions you can take to comply with your fiduciary obligations.

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