Retirement Plan Fee Disclosure – Action Needed

There are two separate, but related, new Department of Labor regulations regarding fee disclosure that will become effective soon: (1) vendor-to-plan disclosure and (2) plan-to-participant disclosure.  The DOL regulations have been finalized and compliance with the vendor-to-plan regulation is required no later than July 1, 2012.  In this alert, we discuss these regulations and provide action items for the immediate attention of retirement plan sponsors and vendors.

Vendor-To-Plan Disclosure

Vendors that serve as plan fiduciaries, registered investment advisors, recordkeepers or brokers, or that provide certain professional services for "indirect compensation," are required to provide detailed fee-related disclosures to the plan fiduciaries responsible for selecting and monitoring them.