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ERISA 408(b)(2) Final Regulations

Compliance with the Department of Labor's final 408(b)(2) regulation, the long-awaited final regulation related to service provider fee disclosures, begins July 1, 2012.

The final regulation makes a number of changes to the disclosure obligation of service providers, some of which provide limited relief though others increase the disclosure requirements. The regulation provides a sample "guide" a service provider can give to a covered plan to assist the responsible plan fiduciary in finding the required disclosures, but use of the guide is not mandatory. 

Our lawyers have authored client alerts on the regulation, focusing on impacts:

05/16/2013

A Pond of Change: Potential Lessons from U.S. Experiences for Competition Reforms in the U.K.

ABA The Civil Practice & Procedure Committee’s Young Lawyers Advisory Panel: Perspectives in Antitrust
Todd N. Hutchison

05/16/2013

OIG Issues Updated Bulletin on Exclusions from Federal Health Care Programs

Drinker Biddle Health Care Insight
Anna Schwamlein Howard, Douglas B. Swill, Jeremy Shapiro-Barr

05/15/2013

Fair Disclosure and Social Media

Client Alert
Troy M. Calkins, J. Joseph Connaughton

05/15/2013

Overlapping Post-Marketing Challenges for Biopharmaceuticals: Pharmacovigilance, Products Liability, and Biosimilars

Life Sciences Law & Industry Report, Bloomberg Services and BioTech Watch
Krista L. Cosner

05/14/2013

“When ‘and’ Really Means ‘or’ in a Restrictive Covenant.”

American Healthcare Lawyer Association e-Newsletter
Rachel Ryan