DOL Issues Clarifying Disclosure Guidance Specifically Question 30

Field Assistance Bulletin 2012-02R supersedes previously issued Field Assistance Bulletin 2012-02 with respect to the now infamous Question 30 by removing Question 30 and inserting a new Question 39 which makes it clear that the DOL intends to engage in discussions with stakeholders regarding these issues.

Document Excerpt

The Department understands plan fiduciaries and service providers may have questions regarding the situations in which fiduciaries may have duties under ERISA’s general fiduciary standards apart from those in the regulation. The Department intends to engage in discussions with interested parties to help determine how best to assure compliance with these duties in a practical and cost effective manner, including, if appropriate, through amendments of relevant regulatory provisions.

Link http://www.dol.gov/ebsa/regs/fab2012-2R.html

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