First, the good news: in July, the Department of Labor extended the deadlines for complying with new retirement plan fee disclosure regulations.

The bad news is that the extended deadlines are right around the corner.

By no later than April 1, 2012, covered service providers for ERISA pension and 401(k) plans must provide plan fiduciaries with specific information on fees and expenses. If a covered service provider fails to comply, the provider’s contract or arrangement with the plan may be considered a prohibited transaction under ERISA and the Internal Revenue Code – even if the fees and expenses are otherwise reasonable.

Although the covered service provider is the party responsible for satisfying the service provider fee disclosure rules, the consequences of noncompliance are shared with the plan fiduciary responsible for causing the plan to enter into the arrangement (in most cases, this is the employer).