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as expected the department of labor recently issued some additional guidance with regard to the participant level fee disclosure obligations under the 404 a5 regulation this guidance we were expecting it came out in the form of a field assistance bulletin namely field assistance bulletin 2012-2 and this fab as we call it had 38 frequently asked questions focusing again primarily on the 4045 obligations now there is expected a second wave of faqs that will focus more closely on the 408 b2 regulation that's the one that requires covered service providers to give certain information about fees and services to a responsible plan fiduciary so that guidance is forthcoming but the guidance we got in the faqs on participant level disclosure should be quite helpful in particular there was one issue that the aspa government affairs committee did write to the department of labor about with regard to the characterization of asset allocation services or model portfolios under the regulation in part

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