Michael Richman

Michael Richman

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IRS and DOL Issue Guidance on Including Deferred Annuities in Target Date Funds

Guidance addresses nondiscrimination, qualified default investment alternative, and annuity safe harbor rules. On October 24, the Internal Revenue Service (IRS) and the U.S. Department of Labor (DOL) each issued...more

11/19/2014 - Defined Contribution Plans DOL IRC IRS New Guidance Target Date Funds Variable Deferred Annuities

DOL Proposes Amendment to Service Provider Fee Disclosure Regulation

Proposal would require certain service providers to furnish a separate disclosure guide. On March 11, the U.S. Department of Labor (DOL) issued a proposed amendment to its 2012 final regulations under section 408(b)(2)...more

3/18/2014 - Disclosure Requirements DOL ERISA Fees

DOL Extends Participant Disclosure Deadline for 2013

Guidance provides temporary relief from the August deadline for annual disclosures by participant-directed plans. On July 22, the U.S. Department of Labor (DOL) issued Field Assistance Bulletin 2013-02 (the Bulletin),...more

7/26/2013 - Benefit Plan Sponsors Compliance Deadlines Delays Disclosure Requirements DOL Enforcement Fee Disclosure Fees

DOL Clarifies Revenue Sharing Fiduciary Responsibility Issues

Advisory opinion on "plan asset" issue lays out factors for fiduciary consideration. On July 3, the U.S. Department of Labor (DOL) issued Advisory Opinion 2013-03A, which discusses whether a bookkeeping account for...more

7/19/2013 - Advisory Opinions Benefit Plan Sponsors DOL ERISA Fiduciary Duty Insurers Revenue Sharing

DOL Clarifies Application of ERISA Rules to Cleared Swaps

New guidance defers to the Dodd-Frank/CFTC framework for regulating the swaps clearing process. On February 7, the U.S. Department of Labor (DOL) issued an advisory opinion on the application of the ERISA fiduciary rules...more

2/15/2013 - Benefit Plan Sponsors CFTC Clearing Members Derivatives Clearing Organizations Dodd-Frank DOL ERISA Fiduciary Duty Prohitibed Transactions Security-Based Swaps Swap Clearing Swaps

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