Plan administrators must provide an initial disclosure to retirement plan participants no later than Aug. 30, 2012. When must the first quarterly statement then be furnished?
C) No later than Nov. 14
According to the Department of Labor, plan administrators are reminded that the final rule's new July 1 effective date also will impact when disclosures must first be furnished under EBSA's participant-level disclosure regulation (29 CFR § 2550.404a-5). The transitional rule for the participant-level disclosure regulation was revised in July 2011 so that the first disclosures would follow the effective date of the 408(b)(2) regulation.
Consequently, for calendar year plans, the initial annual disclosure of "plan-level" and "investment-level" information (including associated fees and expenses) must be furnished no later than Aug. 30, 2012 (i.e., 60 days after the 408(b)(2) regulation's July 1 effective date).
The first quarterly statement must then be furnished no later than Nov. 14, 2012 (i.e., 45 days after the end of the third quarter (July through September), during which initial disclosures were first required). This quarterly statement need only reflect the fees and expenses actually deducted from the participant or beneficiary's account during the July through September quarter to which the statement relates.