"Not the DOL’s 'Final Answer' on Fee Disclosure: Interim Final 408(b)(2) Regs Delayed Until 2012"

On February 11, the Department of Labor ("DOL") announced that it was delaying the effective date of Interim Final rules issued under Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended ("ERISA").  These rules would require certain detailed disclosure by service providers to plans covered by ERISA – or face the prospect of nonexempt prohibited transaction and excise tax liability. 

This Stroock Special Bulletin looks at the announcement, which indicates any final pronouncement will not be effective prior to January of 2012, and some of it's possible implications.