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SEC Reopens Comment Period for Pay-for-Performance Proxy Disclosure

Seyfarth Synopsis: Back in 2015, the U.S. Securities and Exchange Commission (“SEC”) issued proposed rules on the pay-for-performance disclosure required under the Dodd-Frank Wall Street Reform and Consumer Protection Act of...more

Extended Loan Rollover Timeline: More Flexibility for Participants and More Complexity for Plan Administrators

Seyfarth Synopsis: The IRS released final regulations, under T.D. 9937, that generally adopt the proposed rules relating to qualified plan loan offsets issued last year, with one modification relating to the applicability...more

To Disclose Or Not During ERISA Administrative Review — The Fourth Circuit Weighs In With An Affirmative Answer

Synopsis: A recent 4th Circuit decision reiterates the importance of aligning a plan fiduciary’s administrative claim and appeal review process with the standards for a “full and fair review” under U.S. Department of Labor...more

With IRS Retraction, Lump Sum Buyout Opportunities for Retirees Are Permitted Once Again

On March 6, 2019, the IRS announced its intention to abandon further efforts, at least temporarily, to prohibit defined benefit plans from offering voluntary lump sum cashouts to retirees who are already in pay status. ...more

"It all sounds very reasonable..." New SEC Guidance Emphasizes Reasonableness and Flexibility in CEO Pay Ratio Disclosure

On September 21, 2017, the Securities and Exchange Commission (the “SEC”) published an interpretative release and related compliance and disclosure interpretations (“C&DIs”) for registrants regarding the CEO pay ratio...more

HHS Fact Sheet on Your Employees’ and Clients’ Rights under HIPAA to Access their Health Information

The Health Insurance Portability and Accountability Act of 1996 (HIPAA), Public Law 104-191, contains extensive rules designed to limit access by non-health plan entities to certain individually identifiable health...more

DOL’s Proposed Rule On Fiduciaries

On April 14, 2015, the DOL issued a new proposed rule to expand the definition of “fiduciary” under ERISA. This is the second time in recent years that the DOL has gone down this path. The first proposed rule (issued in 2010)...more

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