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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).

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