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Final Fee Disclosure Regulation: Additional Hurdles for Service Providers and Plan Fiduciaries by Michael K. Blais
Jones Day - Dallas Office
Daniel C. Hagen
Jones Day - Cleveland Office
Alan S. Miller
Jones Day - New York Office
Evan Miller
Jones Day - Washington Office
Sara R. Pikofsky
Jones Day - Washington Office
Steven J. Sacher
Jones Day - Washington Office
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February 10, 2012
Previously published on February 2012
On February 2, 2012, the Depar tment of Labor (“DOL”) released the much-anticipated final regulation on service provider fee disclosures. Although the DOL had issued an interim final regulation in July 2010 (see “Fee Disclosure Regulation: Department of Labor Provides Leverage for Plan Sponsors” Jones Day Commentary, August 2010), at that time the DOL also requested additional public comments, leading to the inference among practitioners that it might make additional significant changes. This, in turn, led to reluctance of service providers to prepare for the impending effective date of the regulation because of uncertainty over the potential changes to the regulation’s July 2010 version. The February 2012 final regulation contains relatively few changes of any significance. In this Commentary, we summarize the provisions of the final regulation, as well as highlight changes made subsequent to the July 2010 interim regulation.
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The views expressed in this document are solely the views of the author and not Martindale-Hubbell. This document is intended for informational purposes only and is not legal advice or a substitute for consultation with a licensed legal professional in a particular case or circumstance. |
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