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Navigating the Impact of the New Fiduciary Rule on Insurers and Producers

On April 23, 2024, the U.S. Department of Labor (the “DoL”) released its final rule (“Fiduciary Rule”) titled Retirement Security Rule: Definition of an Investment Advice Fiduciary (an “Investment Advice Fiduciary”), which...more

The DOL’s Final Investment Advice Fiduciary Rule Is Here

In its latest attempt in a fourteen-year old quest to update the circa-1975 definition of a fiduciary who renders “investment advice for a fee or other compensation, direct or indirect” (an “investment advice fiduciary”)...more

Proposed Changes to Voluntary Fiduciary Correction Program (VFCP): DOL Adds Self-‎Correction for Late Deposits of 401(k)...

In November 2022, the U.S. Department of Labor (DOL) proposed changes to its Voluntary Fiduciary Correction Program (VFCP). VFCP allows plan sponsors to voluntarily correct certain fiduciary breaches to avoid civil...more

U.S. Department of Labor Clarifies Extension of Certain Employee Benefit Deadlines Due to COVID-19

As discussed in our prior blog post, on April 28, 2020, the Employee Benefits Security Administration, U.S. Department of Labor, Internal Revenue Service, and Treasury Department (the “Agencies”) published joint guidance...more

Helpful New Guidance on Locating Missing and Nonresponsive Retirement Plan Participants

It is important to note that, since this guidance was issued in the late days of the Trump administration, the Biden administration will likely review this guidance. It is not uncommon for guidance to be delayed, revised,...more

New ERISA Safe Harbor Expands Opportunities for Electronic Disclosure of Retirement Plan Information

On May 21, 2020, the U.S. Department of Labor (“DOL”) announced a new safe harbor rule that will allow plan sponsors, by default, to post retirement plan disclosures online or deliver them to participants by email in...more

Retirement Plan Loans and COVID-19: U.S. Department of Labor Fiduciary Relief and IRS Notice Allowing Short-Term Delay of Plan...

As we discussed in our recent article, the Coronavirus Aid, Relief and Economic Security Act (“CARES Act”) temporarily increases the permissible loan amount for loans taken by qualified individuals between March 27, 2020 and...more

U.S. Supreme Court’s 2019-2020 Term Includes Three ERISA Cases

It has been several years since the US Supreme Court issued a decision in a case involving the Employee Retirement Income Security Act of 1974 (ERISA). In the upcoming term, the U.S. Supreme Court has agreed to review three...more

First Circuit Holds Affiliated Investment Funds Not Liable For Multiemployer Withdrawal Liability

Private equity fund sponsors can breathe a sigh of relief last week as the First Circuit Court of Appeals, reversing a district court finding, held that two separate private equity funds sharing a general partner (Sun Capital...more

Fifth Circuit Issues Mandate to Vacate DOL’s Fiduciary Rule

On June 21, 2018, the United States Court of Appeals for the Fifth Circuit issued its mandate to formally vacate the US Department of Labor’s conflict of interest rule (the “DOL Fiduciary Rule”) and related exemptions,...more

DOL Issues Final Fiduciary Rule: How Does The New Definition Affect Plan Sponsors

On April 8, 2016, the Department of Labor (DOL) issued its final regulations significantly redefining the standards for determining when an adviser is a fiduciary under the Employee Retirement Income Security Act of 1974, as...more

Locke Lord Article: The Best Interest Contract Exemption

In connection with publication of final regulations (the Rule) on the definition of “fiduciary” under the Employee Retirement Income Security Act of 1974, as amended (ERISA) and the Internal Revenue Code of 1986, as amended...more

Department of Labor Publishes New Fiduciary Rule Affecting Retirement Account Advisers

On April 8, 2016, the United States Department of Labor (Department) published its long-awaited final regulations (the Rule) redefining who is a “fiduciary” of an employee benefit plan under the Employee Retirement Income...more

More Worries For Private Equity Funds - Another Structuring Fix Against ERISA Withdrawal Liability Dismantled

In a landmark benefits decision, a Federal District Court in Massachusetts held that separate private equity funds sharing a general partner are jointly and severally liable under the Employee Retirement Income Security Act...more

Same-Sex Marriage is Legal – Are Your Employee Benefit Plans Up to Date?

What is the Supreme Court’s holding in Obergefell v. Hodges? LB: The U.S. Supreme Court ruled that all states must license a marriage between two people of the same sex and all states must recognize a lawful same-sex...more

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