For some time now you have been reading about additional disclosures that service providers will be required to make to you as fiduciaries (“408(b)(2) disclosures”), as well as additional disclosures that your plan will be required to make to plan participants (“participant disclosures”).
The good news is that your service providers have been gearing up to either meet, or help you meet, these requirements. Many of them are primed to do so already. However the Department of Labor (DOL) recently delayed the effective date for both types of disclosures. The 408(b)(2) disclosures’ (from the service provider to the plan) effective date has been moved from January 1, 2012 to April 1, 2012.
In addition, the participant disclosures’ (from the plan to its participants) effective date has been moved (for calendar year plans) to May 31, 2012 (with quarterly disclosures likely provided by August 14, 2012).
If your plan is not a calendar year plan, please contact your retirement plan consultant for further information that may be relevant to your plan. Also be advised that your plan consultant should be contacting you to help prepare your team for the impact of both sets of disclosures toward the end of 2011 and into the beginning of 2012. As always, we’ll keep you apprised of any more developments regarding the disclosures as they occur.