The Investment Lawyer

Are You Ready to Comply with the DOL’s New Disclosure Regime? 
January 2011
Published by David Kaleda, Partner, Alston & Bird LLP; (202)239-3329

At the time this article is published, covered service providers will have about seven months to assure they are in compliance with the Department of Labor’s (DOL) Interim Final Rule on a Reasonable Contract or Arrangement under Section 408(b)(2)-Fee Disclosure(the IFR).   The disclosure requirements are more extensive than those under current regulations and will require evaluation of current disclosure procedures. If the IFR’s requirements are not met, potentially significant excise taxes may be assessed. 

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Two weeks after this was published the DOL extended the compliance deadline from July 2011 to January 1, 2012.