As plan sponsors should be aware, the Department of Labor recently issued new fee disclosure rules. Plan sponsors should have received, by July 1, 2012, the required disclosures from their covered service providers. The obligation is now on the plan sponsor to take action. The plan sponsor must review the disclosure to determine whether required fee disclosures have been received from all service providers and whether the disclosure includes all required information. After satisfying themselves that all required information has been received, plan sponsors must determine whether each service arrangement is reasonable in light of the fee information that has been disclosed.
Fortunately, this should be a fairly easy process for plan sponsors.