On February 2, 2012, the U.S. Department of Labor (the
"DOL") issued final regulations under
ERISA's "necessary services" exemption (the
"Final Regulations"). The Final
Regulations require that certain service providers to pension plans
disclose, before any service arrangement becomes effective, a
variety of details regarding the services they will provide and the
direct and indirect compensation they will receive. Failure to
comply with the Final Regulations could result in a service
provider's arrangements with, and receipt of fees from, a
pension plan constituting a prohibited transaction. The Final
Regulations become effective on July 1, 2012 and will apply to
arrangements entered into both before and after that date. The
Final Regulations generally follow the interim final regulations,
which were released by the DOL on July 16, 2010. A copy of the
Final Regulations marked to show the differences between the
interim final regulations and the Final Regulations can
