On February 2, 2012, the Department of Labor (“DOL”) issued a final rule (the “Final Rule”) on the disclosures required to be made by retirement plan service providers to plan fiduciaries regarding their fees and potential conflicts of interest (the “Service Provider Disclosure Rules”). The DOL originally issued an interim final rule on the Service Provider Disclosure Rules on July 15, 2010. The July 16, 2010 SGR Client Alert addressing the interim final rule can be accessed by clicking here.

The Final Rule further extends the applicability dates for both the Service Provider Disclosure Rules and the rules requiring plan administrators to disclose information about plan and investment costs to participants in participant-directed individual account retirement plans, such as 401(k) plans. The October 25, 2010 SGR Client Alert addressing the participant disclosure rules can be accessed here.

The DOL had previously extended the applicability dates of the Service Provider Disclosure Rules from January 1, 2012 to April 1, 2012, with initial disclosures to participants due 60 days later (May 31, 2012). The Final Rule extends the applicability date for the Service Provider Disclosure Rules to July 1, 2012. As a result of this extension, the initial disclosures to participants are now due no later than August 30, 2012.

For more information, please contact your SGR Executive Compensation and Employee Benefits counsel.