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ARTICLE · 22 JUNE 2011

The DOLs 408(b)(2) Regulation: Impact On Investment Managers

Drinker Biddle & Reath LLP
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This alert discusses the impact on investment managers of the Department of Labor’s (DOL) "interim final" regulation under ERISA §408(b)(2).

United StatesStrategy
Frederick Reish
Frederick Reish
Bruce Ashton
Bruce Ashton

This alert discusses the impact on investment managers of the Department of Labor's (DOL) "interim final" regulation under ERISA §408(b)(2). Our reference to "investment managers" is intended to cover those investment advisers who have discretionary management authority over "plan assets" directly or through vehicles such as collective investment funds, hedge funds or partnerships that are deemed to hold plan assets. The regulation is effective for all relationships in effect on January 1, 2012, and all new relationships entered into on or after that date. In light of the severe adverse consequences of a failure to comply with the new disclosure requirements, we are making investment managers aware of their obligations and counseling them as to the steps to take to comply with the new regulation.

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