When I was about 12, New York was the first state to implement a mandatory seat belt law. Original adherence to the law was negligible because getting people used to driving with a seat belt when they never did was tough. At the time, police could only issue a seat belt ticket if there was another reason to pull you over. Observance to the law grew over time, mainly because drivers like me (those who got licenses after 1985) were required to wear seat belts during driver education. Compliance is now about 91%, which is pretty amazing since pre-law, it was about 16%.
With the six month anniversary of plan sponsor fee disclosure under Section 408(b)(2), you will see and read a lot of claims that it’s been a failure because most plan sponsors don’t read them.
Rome wasn’t built in a day and when you have plan sponsors that were trained to look at absolutely nothing and that fees really didn’t matter, its going to take some time to understand what these disclosures are and their responsibilities concerning them. I’m sure 6 months after the seat belt law, people were claiming in New York that it was a failure. I have said that the impact of fee disclosure will take some time, I would prescribe to belief that we need at least 3-5 years to understand its impact with plan participants, plan sponsors, and the plan providers who provide them.