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DOL Rescinds 2022 Guidance Cautioning Against 401(k) Plan Investments in Cryptocurrencies

On May 28, 2025, the Department of Labor (“DOL”) issued Compliance Assistance Release No. 2025-01 which rescinds the DOL’s prior Compliance Assistance Release No. 2022-1 which had warned 401(k) plan fiduciaries against adding...more

Eleventh Circuit Confirms Foreign Tax Credits Owned by Insurance Company Not “Plan Assets” of 401(k) Plan Under ERISA

In late October 2024, the United States Court of Appeals for the Eleventh Circuit ruled in Romano v. Hancock Life Insurance Company, F.4th 729 (11th Cir. 2024) that certain foreign tax credits that were generated as a result...more

The Never-Ending Fiduciary Rule Story Continues: Effective Date of DOL’s Newest Fiduciary Investment Advice Rule Delayed by...

The Department of Labor (“DOL”) recently issued final rules (the “Final Rules”) which expanded what it means to provide fiduciary “investment advice” under ERISA and Section 4975 of the Code (discussed here). The Final Rules...more

Goodbye “Five-Part Test”—DOL Finalizes New Investment Advice Fiduciary Rules

On April 23, 2024, the Department of Labor (“DOL”) issued final rules which expand what it means to provide fiduciary “investment advice” under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and...more

A Guide to the DOL’s New Investment Advice Fiduciary Rule Proposal – What Investment Advisers and Managers Need to Know

The new “retirement security rule” package, issued by the U.S. Department of Labor (the “DOL”) on October 31, 2023, is the latest chapter in an almost 15-year effort by the DOL to amend the five-part test in its 1975...more

Game of Tomes: A Guide to the DOL’s Retirement Security Rule Proposal

The new “retirement security rule” package, issued by the U.S. Department of Labor (the “DOL”) on October 31, 2023, is the latest chapter in an almost 15-year effort by the DOL to amend the five-part test in its 1975...more

TRICK-or-TREAT? DOL Proposes Spooky New “Retirement Security Rule” That Would Expand the Scope of Fiduciary “Investment Advice”

Responding to the “terrifying” reality that conflicted investment advice is costing retirement savers billions of dollars each year, on October 31, 2023, the Department of Labor (“DOL”) issued proposed rules representing its...more

Special DOL Proxy Voting Rules Set to Take Effect on December 1, 2023 – Potential Action Items for ERISA Plan Fiduciaries

In late 2022, the U.S. Department of Labor (the “DOL”) issued final regulations (the “Final Rules”) which address the extent to which ERISA plan fiduciaries may consider environmental, social and governance (“ESG”) factors...more

DOL Statement on Private Equity Investment Emphasizes Fiduciary Responsibility

On December 21, 2021, the Department of Labor (the “DOL”) published a Supplemental Statement (the “Supplemental Statement”) to its June 3, 2020 Information Letter (the “2020 Letter”) addressing fiduciary considerations for...more

DOL Information Letter Outlines Fiduciary Considerations for Including Private Equity Allocations in Defined Contribution Plan...

On June 3, 2020, the Department of Labor (the “DOL”) published an Information Letter confirming that investment options under a defined contribution plan (e.g., a 401(k) or 403(b) plan) may include a limited allocation to...more

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