SPARK Releases Final Data Standards for Fee Disclosures

The SPARK Institute released its final version of data layouts for sharing investment-specific information for non-registered investment products that retirement plan administrators must disclose to participants under the DoL’s participant disclosure regulations.

Larry Goldbrum, General Counsel, noted a draft version was released in July for public comment (see “SPARK Creates Data Standards for Participant Fee Disclosure“) and a number of relevant changes have been made as a result of comments received.  

The data layouts are designed for non-registered investment product providers (e.g., bank collective investment funds, non-registered “fund of funds,” separately managed accounts and annuities), because no standards or mechanisms currently exist for these investment providers to transmit the required information to retirement plan recordkeepers, investment fund aggregators, and other parties who may assist plan administrators with disclosure of the information to plan participants, according to SPARK.  

“A significant amount of information must be shared by investment providers on potentially thousands of non-registered investments in order for plan administrators to be able to comply with the participant disclosure rules. Sharing the required information electronically through recordkeepers and data aggregators using the Data Layouts will be particularly helpful to plan administrators because it will be the most reliable and cost efficient means of doing so,” Goldbrum said. “We are releasing a final version now so that potential users can begin preparing and programming to use it well in advance of the participant disclosure rules compliance date of April 1, 2012.”    

The data layouts document, “Data Layouts for Non-Registered Investment Product Disclosures to Retirement Plan Participants,” is posted at