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Legal Update

Department of Labor Expands Annual Reporting Requirements for Service Provider Compensation

12 March 2010
Mayer Brown Legal Update
On November 16, 2007, the Department of Labor (DOL) published a revised Form 5500 applicable to most plans governed by the Employee Retirement Income Security Act of 1974 (ERISA), as well as accompanying regulations. Among other changes, the new Form 5500 includes a revised Schedule C that requires significantly expanded reporting of direct and indirect compensation received by (i) service providers to the plan, (ii) other persons, if eligibility for a payment or the amount of the payment is based, in whole or in part, on services that were rendered to the plan or on a transaction or series of transactions with the plan, and (iii) service providers to mutual funds, private investment funds, bank collective trusts and insurance company separate accounts in which a plan holds an interest.

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