It didn’t have a big box office in 1986 when it was released, but the ¡Three Amigos! movie has gone on to become a comedy classic. And how could it not,
- Written by Steve Martin, Lorne Michaels, and Randy Newman
- Directed by John Landis
- Starring Steve Martin, Chevy Chase, and Martin Short
- Supporting roles played by the late Phil Hartman, John Lovitz, and Joe Mantega (Chicago guy!)
- Original music by the late Elmer Bernstein
Now let’s fast forward 22 years to today’s headline, ¡Three Amigos! of 401(k) Fee Disclosure Opening At A Retirement Plan Near You Soon. And in the starring roles (drum roll please) will be:
1. New Reporting Requirements for Schedule C of the 2009 Form 5500. Effective January 1, 2009, the Department of Labor (DOL) will be requiring new and extensive disclosures for service provider fees and other compensation. How extensive? See for yourself. Here’s a link to the DOL’s FAQs About The 2009 Form 5500 Schedule C. Nick Curabba on Baker & Daniels’ Benefits Biz Blog gives us some help in his post, DOL’s New Thinking on Schedule C.
2, The DOL’s proposed amendments to the service provider fee disclosure regulations under Section 408(b)(2) of ERISA. The new regulations mandate disclosures of compensation and conflcts of interest by plan service providers. The effective date will be 90 days after the final regulation is published in the Federal Register. It’s possible that the DOL will make the effective date coincident with the January 1, 2009 Schedule C date discussed above.
3. The DOL’s proposed regulations released July 23 that would impose new requirements for the disclosure of fee and expense information to participants in self-directed retirement plans, i.e., 401(k) plans. The proposed regulations would be effective for plan years beginning on and after January 1, 2009. At the same time, the DOL proposed changes to the regulations under Section 404(c) of ERISA that would incorporate these new disclosure requirements.
The DOL is, of course, the producer/director of these new ¡Three Amigos!. But unlike the original, this isn’t a comedy. And unlike the orignal, viewing isn’t discretionary – it’s required.
