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Service Provider Fee Disclosure Final Regulation and Participant Level Fee Disclosure Final Regulation

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Lauren B. Dunn
Foster Swift Employment, Labor & Benefits Quarterly
Summer 2012

The U.S. Department of Labor ("DOL") published the final Service Provider Fee Disclosure Regulation (the "Final Regulation") on February 3, 2012. The Final Regulation requires that certain retirement plan vendors who supply services to a "covered plan" (generally, an ERISA employee benefit plan) disclose certain information to the employer sponsor with regard to the compensation that is received by the vendor for the performance of those services. The Final Regulation effective date is July 1, 2012 (the " Effective Date").

The Effective Date also affects the date when a plan sponsor must make initial disclosures of certain fee information to retirement plan participants under the final Participant Level Fee Disclosure Regulation (the "Participant Level Fee Disclosure Regulation"). Because of the Effective Date, initial disclosures under the Participant Level Fee Disclosure Regulation for a calendar year plan must be furnished to plan participants not later than August 30, 2012. Plan sponsors of calendar year plans must also furnish the first required quarterly disclosure to plan participants not later than November 14, 2012.