New ERISA Disclosure Requirements Applicable to Plan Assets Funds and Investment Management Arrangements
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- Under recently issued regulations by the department of labor, investment managers providing services to a defined benefit or defined contribution plan or to a "plan assets" fund will be required to provide the responsible plan fiduciary of an ERISA plan investor with extensive disclosure concerning direct and indirect compensation.
- Existing arrangements will need to be reviewed to ensure compliance with these new requirements, which are effective July 1, 2012.
- Non-compliance with these requirements may result in such arrangements being characterized as a prohibited transaction with excise taxes and other potential liabilities imposed on the investment manager.