On July 30, 2012, the Department of Labor issued FAB 2012-02R as a revised version of FAB 2012-02 (issued May 7, 2012), which supplements the participant-level fee disclosure regulation and how it may be implemented. (See our prior post regarding FAB 2012-02.)

Q&A 30 of FAB 2012-02 generated significant controversy as it appeared to introduce

On May 7, 2012, the DOL published Field Assistance Bulletin 2012-02 (the “FAB”) providing additional guidance and clarification for employers and other plan fiduciaries regarding the participant-level fee disclosure regulation (29 CFR 2550.404a-5) applicable to participant-directed individual account plans (e.g., 401(k) and 403(b) plans; see our earlier article regarding these regulations).  The FAB is also