ERISA Section 408(b)(2) Fee Disclosures: Impact on Broker-DealersMarcia S. Wagner, Esq
The U.S. Department of Labor's ("DOL") final regulations (the "Final Regulations") under Section 408(b)(2) of ERISA (the "necessary services exemption") will go into effect on July 1, 2012 (the text of the Final Regulations may be accessed h...
Long-Term, Part-Time Employee Guidance for Section 403(b) Plans (and Two-Year Extension for 401(k) Regulations) Groom Law Group, Charteredon10/14/2024 On October 3, 2024, the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) issued Notice 2024-73 (the...
The final regulation also noted that there may be "extraordinary situations when fiduciaries will have a disclosure obligation beyond those addressed" in this regulation, including the requirement as to timing of the required disclosures described below. As an example, the regulation refers to a situa...
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types of services referenced immediately above for fearthat too much specificity might narrow the application of the regulation; thus, serviceproviders providing similar services should carefully evaluate whether disclosures arenecessary as this category of Covered Service Provider may be interpreted broadly....
It states that the Employee Benefit Security Administration published its final rule addressing disclosures that service provider must provide to plan fiduciaries. It addresses the primary questions may ask regarding the information that must be disclosed in accordance with the final rule.Weisberg...
Purpose – The purpose of this paper is to explain the US Department of Labor's final regulations under Section 408(b)(2) of ERISA, concerning the fact that information investment advisers to ERISA-covered pension plans and private investment funds deemed to hold the "plan assets" of ERISA-...