Once Is Not Enough: Ongoing Fee Disclosure Obligations Under ERISA

Firms that manage ERISA plan assets are subject to the US Department of Labor regulations on fee disclosures. In addition to the initial fee disclosure, these regulations require disclosure of changes to fee information previously provided to plan fiduciaries. This client publication describes the requirements for reporting such changes to plan fiduciaries.

Firms that manage separate accounts or funds that hold assets of ERISA plan clients are subject to ongoing disclosure obligations to these clients under the fee disclosure regulations of the US Department of Labor (the "DOL"). It has been nearly a year since the DOL's regulations on service provider fee disclosures first became effective. These regulations required asset managers and certain other service providers to ERISA plans to provide their plan clients with detailed disclosures related to the direct and indirect fees charged to the plans. The regulations resulted in a round of fee disclosures to existing