DOL Retirement Plan Fee and Expense Disclosure Compliance

Navigating New Rules for Service Providers and Plan Sponsors

Recording of a 90-minute CLE webinar with Q&A

Conducted on Tuesday, March 27, 2012

Recorded event now available

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Program Materials

This CLE webinar will provide benefits counsel with an analysis of the DOL’s new fee and expense disclosure regulations for providers and disclosures to plan participants, provide best practices for compliance, and outline the obligations for both plan service providers and sponsors.


The long-awaited final regulations for retirement plan provider fee and expense disclosures have been released and the compliance deadline extended until July 1, 2012. A provider who fails to comply will have its contract with the plan deemed a prohibited transaction under ERISA with adverse tax consequences.

The onus now shifts to plan sponsors to provide participants with enhanced fee disclosures by Aug. 30, 2012. Sponsors must issue reports quarterly and annually providing investment information and the fees and expenses charged by the provider and charged to participants.

Plan sponsor obligations are further complicated because they must not only ensure the provider's disclosures comply with new regulations, but they must also review the provider’s compensation structures and verify that fees and expenses are “reasonable.”

Listen as our authoritative panel of ERISA attorneys guides counsel for service providers and plan sponsors through the new fee and expense disclosure requirements and discusses best practices for compliance.



  1. Section 408(b)(2) fee disclosures from service providers to plan sponsors
  2. Section 404(a)(5) disclosures by plan sponsors to participants
  3. Compliance challenges and best practices


The panel will review these and other key questions:

  • What additional requirements or clarifications do the final Section 408(b)(2) regulations provide in contrast to the interim regulations?
  • What are the consequences for service providers that fail to comply with the new regulations?
  • What relief is available to a plan sponsor for a compliance failure of its service provider?
  • How have the service provider disclosure rules and the participant-level disclosure rules been coordinated to facilitate compliance?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Michael B. Richman
Michael B. Richman

Of Counsel
Morgan Lewis & Bockius

He practices in employee benefits and the investment management and securities areas. He principally focuses on...  |  Read More

Daniel R. Kleinman
Daniel R. Kleinman

Morgan Lewis

His practice focuses on ERISA fiduciary responsibilities and related tax, corporate and securities laws in connection...  |  Read More

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