New Form 5500 Rules Greatly Increase Information Required To Be Disclosed About Compensation Received By Service Providers To Plans Subject To ERISA

January 10, 2008

On November 16, 2007, the Department of Labor, Internal Revenue Service and Pension Benefit Guaranty Corporation jointly issued new rules that require greatly expanded disclosure of compensation received by persons who provide services to employee benefit plans subject to the Employee Retirement Income Security Act of 1974, as amended. The new rules are contained in revisions to Schedule C (Service Provider Information) of Form 5500 (Annual Return/Report of Employee Benefit Plan).

Attached is a memorandum that summarizes the new rules and suggests a handful of action items that we believe deserve prompt attention. Links to the new rules and the relevant instructions are below.

http://www.dol.gov/ebsa/regs/fedreg/final/20071116.pdf
http://www.dol.gov/ebsa/regs/fedreg/notices/20071116.pdf

Please contact any of our partners or counsel listed under the Employee Benefits section of this website for additional information.