Like so many things, in benefits and in life, there are two sides to every coin. For example, while new 408(b)(2) regulations governing service-fee disclosures are expected to help retirement plan sponsors determine fee reasonableness and assess conflicts, once the July 1 deadline passed, the burden of responsibility shifted to the employer.

As of July 2, plan sponsors are required to collect and review disclosures from all covered service providers that have and have not provided the required disclosures. Covered service providers must report whether they are a fiduciary, the services they will render for the plan and the fees they will receive - both direct and indirect - and the manner in which they receive their compensation.

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