The U.S. Department of Labor (DOL) issued an interim final rule last year
requiring that certain service providers to ERISA-covered retirement plans
furnish specialized disclosures to those plans’ fiduciaries. On Feb. 11, 2011,
the DOL announced that it is delaying implementation until Jan. 1, 2012, in
order “to ensure a careful review of all the valuable input we received on the
interim final rule, including suggestions for a summary document to further
assist plan fiduciaries in their review of furnished information.” The interim
final rule (originally to take effect July 16, 2011) interprets Section
408(b)(2) of ERISA, which exempts reasonable arrangements for plan
administrative services from ERISA’s prohibited transaction restrictions.
For more information and discussion of the considerations the interim final
rule raises for retirement plan fiduciaries, see our
legal update on this topic.