April 1, 2012, is a significant date for plan sponsors and their plan committees. By that date, they should have received – and will need to begin evaluating – information from their plan’s service providers under a newly effective U.S. Department of Labor regulation. That regulation (the 408(b)(2) regulation) requires plan service providers to make disclosures – about their services, compensation and fiduciary status – to their clients (the responsible plan fiduciary) by April 1 of next year. As a result, starting next spring, plan sponsors will face heightened expectations and legal responsibilities.
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