408(b)(2) Final Dates
Posted on Tue, Feb 07, 2012
The final date for 408(b)(2) compliance is July 1st, 2012.
408(b)(2) regulations require that service providers, to retirement plans that are subject to ERISA, make a written disclosure of their total compensation, services, fiduciary & RIA status.
It has been generally accepted that amendments to the 408(b)(2) regualtions would be forthcoming as the DOL was still inviting comments and the regualtion itself was in “interim final” status. In August of this year, the DOL publicly announced that it was working on an amendment and as a result extended the compliance date. Now, in issuing the final rule, the compliance date has once again been extended, though for only three months.
Service providers should note July 1, 2012 on their calendars to make sure they are in full compliance by that date for existing clients and that they are prepared to comply with advance disclosures for any new clients.
