"DOL Effects Effective Date Changes For Two Important Fee Disclosure Rules"

On July 13, 2011, the Department of Labor ("DOL"), extended and aligned the effective dates of two important rules applicable to plans subject to the Employee Retirement Income Security Act of 1974, as amended ("ERISA"), in response to concerns expressed by commenters.  This Stroock Special Bulletin briefly discusses the new effective dates, which are intended to assist plan fiduciaries and plan administrators in bringing into compliance contracts under Section 408(b)(2) of ERISA before turning to compliance on participant-level disclosure, and to give more time to accomplish these tasks.