The Department of Labor recently announced that it will delay the start date of new retirement plan regulations to Jan. 1, 2012. These regulations, originally scheduled to take effect on July 16, 2011, are designed to improve the transparency and disclosure of service provider fees and conflicts of interest applicable within certain employer-sponsored retirement plans.

The delay will give the affected service providers more time for compliance. Specifically, the DOL's rules will require all service providers to certain employer-sponsored retirement plans to disclose all compensation in excess of $1,000, whether paid directly or indirectly, along with a detailed overview of services rendered. The rules also require disclosure of any inherent conflicts of interest.

The goal is to ensure plan fees are reasonably comparable to services rendered. Violations can result in significant liability for the plan's fiduciaries.

This delay will now dovetail implementation with new, separate participant-level fee disclosure mandates forthcoming under DOL regulation 404(a)(5) for plan years beginning after Nov. 1, 2011.

Regardless of this delay, plan sponsors should review all aspects of their plans now, in order to be out in front of these new regulations if change is warranted. A complete fiduciary review should include analysis of employee participation; participant education and advice being provided; whether the plan has an adequate Investment Policy Statement (IPS) that clearly defines how investments are chosen, reviewed and eliminated from the menu of available options; all costs and fees; and whether automatic enrollment is effectively utilized.

These are just a few of the best practices to consider in an effective fiduciary oversight process.

-- Jeff Acheson, Schneider Downs Wealth Management Advisors, jacheson@schneiderdowns.com