"DOL Proposes Harmonization of Effective Date of Fee Disclosure Rules"

On May 31, 2011, the Department of Labor ("DOL") proposed to harmonize the effective dates of two fee disclosure rules applicable to plans subject to Title I of the Employee Retirement Income Security Act of 1974, as amended ("ERISA").  The first is the "interim final" rule, issued under Section 408(b)(2) of ERISA, which will require certain service providers to plans subject to ERISA to report all items of direct and indirect compensation they receive under detailed rules.  The expected effective date of this rule is January 1, 2012, although the DOL has yet to provide final regulations.  The second relates to requirements imposed on plan sponsors of 401(k) (and similar) plans to provide detailed information concerning certain plan level and investment level information . This rule had an original first date of applicability for plan years beginning on or after November 1, 2011. 

This Stroock Special Bulletin provides an overview of the DOL's proposal.