For most defined contribution plans, initial annual fee
disclosures are due to participants by August 30, 2012. In
order to facilitate compliance with the new fee disclosure rules,
the U.S. Department of Labor recently issued Field Assistance
Bulletin 2012-02, which provides helpful commentary on 38 common
disclosure questions, including disclosure of administrative
expenses and brokerage window fees.
As described in our
November 5, 2010, newsletter, recent U.S. Department of Labor
(DOL) regulations require plan administrators to make significant
disclosures regarding plan fees to participants in 401(k), 403(b)
and other defined contribution plans that have participant-directed
investments. For most plans, including calendar year plans,
the initial annual disclosure is due to participants, beneficiaries
and other eligible employees (collectively referred to in this
article as "participants") by August 30, 2012. To
facilitate compliance with the fee disclosure
