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D NEW DISCLOSURE REQUIREMENTS FOR RETIREMENT PLANS By Martha S. Bethea, CPA OES YOUR PRACTICE sponsor a qualified retirement plan (profit sharing, 401(k), or pen- sion plan)? If so, it is likely that your plan is subject to new disclosure requirements effective this year. It is not possible in this brief article to go through a detailed analysis of which plans are subject to reporting and what the specific reporting requirements are. My goal is to share with you enough information so you can address whether your plan must to take action prior to the upcoming due dates. There are two forms of disclosure requirements with separate due dates. By July 1, 2012, covered service providers must disclose information regarding their services and compensation for such services to the responsible retirement plan fiduciaries. In turn, the responsible retirement plan fiduciaries must provide annual participant-level disclosures by August 31, 2012 for calendar year plans. They also must also provide the first quarterly disclosures to plan participants no later than November 14, 2012. In very general terms, the covered service providers include fiduciaries and investment advisors, providers of recordkeeping or brokerage services and direct providers of service who receive indirect compensation. The information that must be disclosed to the retirement plan fiduciary includes a description of the services provided along with information on how the service provider is compensated and the form of payment. These disclosures would then be used by the retirement plan fiduciary as part of their reporting obligations to plan participants. The retirement plan fiduciary must pro- vide three areas of information to the plan participant 1) general plan information 2) administrative expense information and 3) individual expense information. General plan information includes information related to plan investments such as: + How to provide investment instruc- tions, including any limitations or restrictions. + What exercise of voting, tender or similar rights the participant has according to the plan document. + Identification of designated invest- ment alternatives offered under the plan. + Ident i f ic at ion of designated investment managers. + Description of any options that enable the participant to select investments beyond those designated by the plan. Administrative expense information includes information regarding all fees for general plan administrative services that may be charged to the individual participants account that are not part of the annual operating expenses of the designated investment alternative. The basis on which these charges will be allocated to the individual accounts must also be disclosed. Individual account charges such as a plan loan fee must also be disclosed. Investment related disclosures include Continued on Page 38