The U.S. Department of Labor (DOL) recently released its proposed rule on a guide for 401(k) fee disclosures. The rule would require service providers to provide guides to employers and other fiduciaries to help them navigate fee disclosures if they are lengthy or multiple documents.
The guide must specifically identify the document, page, or, if applicable, other sufficiently specific locators, such as section, that enables the responsible plan fiduciary to quickly and easily find the specified information, as applicable to the contract or arrangement. The proposed provision requires a specific locator, including the identity of the document and where the information is located within the document.
We are currently working on a comment letter to send to the DOL because of the negative impact on firms who often use multiple documents to make their disclosures and may need to hire outside companies in order to accommodate the new requirements.