Stroock Special Bulletin
"K.O.'d by New 401(k) Disclosure Rules? One Year to Get off the Mat"
On October 14, 2010, the Department of Labor released final regulations (the "Final Regulations"), which will affect plan sponsors of participant-directed account plans such as 401(k) plans Section 403(b) plans and their service providers, such as investment managers, fund complexes, broker-dealers, custodians, administrators and others. The Final Regulations will require the provision of detailed plan- and investment-related information for plan years beginning on or after November 1, 2011. Individual retirement accounts, SEP plans and SIMPLE plans are excluded from the Final Regulations, but there is no general exception for small plans.
This Stroock Special Bulletin highlights some of the potential challenges for plan sponsors and service providers raised by the Final Regulations. The attached chart sets forth selected aspects of the required disclosure in greater detail.