The DOL issued final 408(b)(2) regulations on February 3, 2012. These regulations provide modifications to the interim final regulations issued in 2010 (see ErisaALERT 2010-11). This ErisaALERT will discuss some of the modifications. We will provide a more extensive discussion at some point in the future. The modifications Effective date – The effective date has […]
2012 archive, 408b2, covered service provider, Disclosure, DOL, fee disclosure, Fee TransparencyReasonable Contract under ERISA 408(b)(2) Disclosure Requirements In 2008, we issued a series of ErisaALERTs discussing the proposed regulations regarding fee transparency (Plan participants, Reasonable Contract, 2009 Schedule C). The Obama administration delayed finalization of the regulations pending the new administration’s review. The wait is over; interim final regulations regarding the Reasonable Contract were issued […]
408b2, Disclosure, ERISA, reasonable contractSeptember, 2008 Fee Transparency Part 2 – Reasonable Contract or Arrangement Under Section 408(b) (2)—Fee Disclosure As noted in Part 1 of our three part Fee Transparency series, there are three pieces of DOL guidance that Plan Sponsors should have on their list of “to dos”. Two are in the form of proposed guidance with […]
408b2, Fee Transparency, reasonable contractAugust, 2008 Fee Transparency Part 1 – Disclosures to Plan Participants There are three pieces of DOL guidance that Plan Sponsors should have on their list of “to dos”. Two are in the form of proposed guidance with the third in final form. Why should you have this on your “to do” list? Because they […]
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