Client Alert

| August 26, 2010

Department of Labor Issues Interim Final 408(b)(2) Regulations Requiring Disclosure of Service Provider Compensation

On July 16, 2010, the Department of Labor (“DOL”) issued an interim final regulation (the “Regulation”) that amends existing regulations defining what constitutes a “reasonable” service contract or arrangement for purposes of Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). Under the Regulation, certain service contracts and arrangements between a pension plan and a party in interest will not be considered reasonable for purposes of Section 408(b)(2) unless the service provider discloses to the plan’s fiduciary certain information regarding the compensation that will be received in connection with the provision of services to the plan.

For more information, please contact your Dewey & LeBoeuf relationship partner, or one of the following:

Howard Adler

+1 212 259 7115

Mitchel C. Pahl

+1 212 259 6720

This memorandum is intended only as a general discussion of these issues. It is not considered to be legal advice. We would be pleased to provide additional details or advice about specific situations. For additional information on this important topic, please feel free to call upon your Dewey & LeBoeuf relationship partner. No part of this publication may be reproduced, in whole or in part, in any form, without our prior written consent. For further information on Dewey & LeBoeuf, please visit www.dl.com. +1 888 532 6383