As most of you have probably heard by now, the Department of Labor (DOL) has extension of time to comply with the ERISA Section 408(b)(2) fee disclosure rules.
The 408(b)(2) requirements are now effective as of April 1, 2012 (instead of July 16, 2011). The extension not only gives all of us in the industry extra time to prepare, but it also gives us a chance to stop, take a deep breath, and assess what our respective disclosure obligations may be, pending release of the final regulations (currently rumored to arrive sometime this fall).
The most challenging aspects of the regulations for the broker/dealer and financial advisor community are also the most basic:
- Am I a covered service provider?
- If so, how do I make my disclosures?
- Is there anyone who can provide this disclosure on my behalf?
As a quick refresher, there are three broad categories of "covered service providers" under the regulations, and a broker/dealer or a financial advisor could potentially fall in any (or all) of the categories:
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