New Department of Labor (“DOL”) regulations obligate certain service providers to pension plans (both defined benefit plans and defined contribution plans (e.g. 401(k) plans)) to make detailed disclosures to “responsible plan fiduciaries.” If these detailed disclosures are not received by July 1, 2012, then the contract (or arrangement) with the covered service provider will be a prohibited transaction under ERISA. Plan sponsors need to check with their plan’s service providers to make sure that the required disclosures will be received on or before July 1, 2012.
