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New Artificial Intelligence (AI) Regulations and Potential Fiduciary Implications

Fiduciaries should be aware of recent developments involving AI, including emerging and recent state law changes, increased state and federal government interest in regulating AI, and the role of AI in ERISA litigation. While...more

Diving Into SECURE 2.0: Changes for Small Employer Retirement Plans

The SECURE 2.0 Act of 2022 (SECURE 2.0) significantly changes the legal and administrative compliance landscape for U.S. retirement plans. Foley & Lardner LLP is authoring a series of articles that take a “deep dive” into key...more

401(K) Compliance Check #11 – Tackling Beneficiary Designations

In last month’s 401(k) Compliance Check, we discussed best practices for drafting a 401(k) plan summary plan description (SPD). This month we provide some best practices for plan administrators’ handling of 401(k) plan...more

401(k) Compliance Check #6: Have You Recently Checked Your 401(k) Plan’s Definition of Compensation for Deferral and Match...

In last month’s Compliance Check, we discussed how to handle a situation where the 401(k) plan administrator is unable to reach a plan participant, i.e., a “missing participant.” In this month’s Compliance Check, we focus on...more

401(k) Plan Top 10 Year End Laundry List

No one really appreciates laundry, but having a calendar year-end top 10 list may be exactly what plan sponsors and administration committees need in order to prevent operational or document compliance issues being raised by...more

Overview of New DOL Guidance for the COBRA Subsidy Mandate – Including Helpful Charts Summarizing New Notice Requirements

Takeaway Message. The Department of Labor (“DOL”) has recently issued model notices and forms that can be used to comply with the new subsidized COBRA requirements created by the American Rescue Plan Act of 2021 (“ARPA” or...more

ERISA/Cybersecurity Considerations in the COVID Age

“Because that’s where the money is,” was the famous quote fictitiously attributed to Willie Sutton when asked why he robbed banks. Given the trillions of dollars held by employee benefit plans, these plans are prime targets...more

The Payroll Tax Deferral Dilemma

On August 8, 2020, President Trump issued an executive order calling for a deferral of the employees’ portion of the payroll tax (the 6.2% Social Security tax only) from September 1, 2020 through December 31, 2020 (the...more

Department of Labor Provides Guidance on Environmental, Social and Governance (ESG) Investing

While employers and workers alike have understandably been extremely focused on coronavirus–related matters, the U.S. Department of Labor (DOL) recently (June 23, 2020) decided that employee benefit plan fiduciaries need to...more

CARES Act – IRS Releases Guidance on Social Security Tax Deferral

On April 10, 2020, the IRS released guidance in the form of an FAQ regarding the ability of employers to delay payment of certain payroll taxes. Under Section 2302 of the CARES Act, employers can delay payment of the...more

ESOP Valuation and Other Considerations in the Age of the Coronavirus

Many corporate clients that currently sponsor employee stock ownership plans (“ESOPs”) are addressing ESOP plan administration matters for the plan year ending December 31, 2019 (or another recent non-calendar plan year-end...more

CARES Act – Summary of Tax Provision

The Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), which was signed by the President on March 27, 2020, includes several provisions affecting taxes. SEC. 2201. 2020 Recovery Rebates for Individuals...more

ERISA Fiduciary Training – Should Employee/Fiduciaries Live Without It?

Every week, new federal lawsuits are filed against companies and individuals, alleging that one or more breaches of fiduciary duties have been committed in connection with responsibilities owed to employee benefit plans...more

DOL Issues Opinion Letter Clarifying Employment Status in Gig Economy

On April 29, 2019, the Department of Labor issued an opinion letter FLSA2019-6. In fall 2018, several employer groups sought clarification from the DOL on worker classification as employees versus independent contractors. In...more

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