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New ERISA Disclosure Requirements Applicable to Plan Assets Funds and Investment Management Arrangements
16 February 2012
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.
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