3980. What is the required format for these disclosures?Connie L Jumprcline212014-06-23T23:44:00Z2014-06-23T23:44:00Z12971693The National Underwriter Company1431987143980. What is the required format for the disclosures that service providers must make under the DOL regulations? The regulations do not require a service provider to follow a specific format in how it discloses required information. One document or several may be involved, especially when a prospectus is available for certain of the investment disclosures. All disclosures must provide the information in a manner that can be understood by the responsible plan fiduciary and participants.Labor Reg. §2550.408b-2(c)(1)(iv)(E). Planning Point: In March of 2014, the Department of Labor released a Proposed Amendment to 408(b)(2) Regulation which, if finalized, will require plan service providers to provide a “guide” to their 408(b)(2) disclosures if the service provider discloses the appropriate information through “multiple or lengthy documents.” The DOL does not give an exact number of pages that would constitute a “lengthy” document, but it is assumed that any final amendment to the regulations would specify an exact number. The guide to the disclosures would need to be provided with the initial 408(b)(2) disclosures and would act as an index to the longer disclosures, allowing plan fiduciaries to quickly identify the information required by the regulations. The guide must include specific lookup references by identifying the page number and document in which the following information can be found:Description of the services to be providedStatement concerning services to be provided as a fiduciary and/or as a registered investment providerDescription of all direct and indirect compensation, any compensation that will be paid among related parties, compensation for termination of the contract or arrangement, as well as compensation for recordkeeping services; andThe required investment disclosures for fiduciary services and recordkeeping and brokerage services, including annual operating expenses and ongoing expenses, or if applicable, total annual operating expenses. PAGE