Besides investment managers, broker-dealers also will feel the pinch of fee disclosure regulations when they go into effect July 1.

According to Fred Reish of DrinkerBiddle, the Department of Labor's 408(b)(2) regulations do apply to broker-dealers because they refer investment managers to plans and receive solicitor's fees in exchange for that service. They also have to disclose those fees to clients.

"It is common that, when an adviser refers an investment manager to an ERISA plan, the adviser will receive a referral fee, which is called a solicitor's fee. In most cases, the adviser will receive a fee for the referral that often continues so long as the plan uses the investment manager. Under the securities laws, the adviser provides a solicitor's fee disclosure statement to the investors," he said.