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DOL Finalizes VFC Program Self-Correction Component for Late Deposits and Loan Failures

On January 14, 2025, the US Department of Labor (“DOL”) released a final regulation revising its Voluntary Fiduciary Correction (“VFC”) Program and related prohibited transaction exemption (“PTE”) 2002-51 to add a...more

ESG in 401(k) Plans in the Wake of Spence v. American Airlines, Inc.

Whether investment decisions for pension, 401(k), and other plans covered by ERISA should be influenced by environmental, social, and governance (ESG) factors has become a flashpoint and, unlike most ERISA issues, the...more

Supreme Court Declines to Clarify Enforceability of Mandatory Arbitration for Fiduciary Breach Claims

Are mandatory arbitration provisions with class action waivers a simple solution to the onslaught of class action litigation that has plagued 401(k) plans in recent years? The results so far have been mixed. Some courts have...more

SECURE 2.0: A Deeper Dive into the Provisions Affecting Defined Benefit Pension Plans

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) includes a number of changes that affect defined benefit pension plans. This includes new reporting and disclosure requirements in connection with offering a lump sum window and...more

IRS Issues SECURE 2.0 Guidance on Expanded Availability of Self-Correction

The SECURE 2.0 Act of 2022 (“SECURE 2.0”) greatly expands the availability of self-correction of compliance failures involving employer retirement plans and IRAs. On May 25, 2023, the IRS issued Notice 2023-43, which...more

DOL Opens ESG Door: What Does It Mean for Plan Fiduciaries?

Department of Labor (“DOL”) Secretary Walsh recently announced final regulations in a blog post titled “Removing Barriers to Considering ESG Factors in Retirement Plan Investments.” While the rules open the door to more...more

DOL to Allow Self-Correction of Late Deposits of 401(k) Plan Deferrals and Loan Repayments

On November 18, 2022, the DOL released proposed text for a revised Voluntary Fiduciary Correction (“VFC”) Program and related prohibited transaction exemption (“PTE”) 2002-51. The most significant aspect of the revised VFC...more

Secure Act 2.0 – Summary of Key Provisions

The House and Senate are moving forward on several versions of legislation, which are collectively known as the “Secure Act 2.0” because they would build off of the Secure Act, the last major retirement plan legislation...more

Supreme Court Upholds ERISA Plan Design for Dialysis Coverage

The Supreme Court released an opinion Tuesday, June 21, 2022, holding that the Marietta Memorial Hospital Employee Health Benefit Plan (“Marietta Plan”) did not violate the Medicare Secondary Payer statute merely because it...more

Supreme Court Affirms Fiduciaries’ Responsibility for Each Investment Option

The Supreme Court today issued a succinct, unanimous opinion in Hughes v. Northwestern University. The Court affirmed that fiduciaries of retirement plans (including university 403(b) plans like Northwestern’s as well as the...more

Fiduciary Duty IS Coming to Privacy – Through Your Benefit Plans!

While all businesses have been grappling with cybersecurity challenges for years, cybersecurity has recently come into focus for retirement plans, health and welfare plans and other ERISA plans due to a new Department of...more

DOL Releases Cybersecurity Guidance

On April 14, 2021, the Department of Labor (“DOL”) issued several pieces of guidance on cyber security best practices, including: (1) a press release, (2) Online Security Tips for retirement plan participants, (3) a Tips for...more

DOL Issues Non-Enforcement Policy for ESG and Proxy Voting Rules

As 2020 drew to a close, the Department of Labor (“DOL”) finalized a number of regulations relating to the fiduciary duties that apply to ERISA plan investments, including: (1) a final rule generally restricting fiduciaries...more

Fiduciary Rule 2.0: What You Need to Know About the DOL's New Fiduciary Rule

On June 29, 2020, the Department of Labor (“DOL”) announced1 its new approach to the standards for financial institutions and investment professionals who provide investment advice on a nondiscretionary basis to 401(k) plans,...more

Overview of the DOL’s New Fiduciary Rules for Retirement Plan Investment Advice

On June 29, 2020, the Department of Labor (“DOL”) announced its new approach to the standards for financial institutions and investment professionals who provide investment advice on a nondiscretionary basis to 401(k) plans,...more

IRS Further Expands Some Deadline Relief for Benefit Plans with Notice 2020-35

The Department of Treasury and Internal Revenue Service (“IRS”) released Notice 2020-35 on May 28, 2020, which extends to July 15, 2020, a growing list of deadlines otherwise applicable to employee benefit plans within the...more

CARES Act - Provisions Applicable to Tax-Qualified Retirement Plans

Emergency Withdrawals. Participants in defined contribution plans (profit sharing, 401(k), and 403(b) plans) could access their retirement savings now if plans are amended to allow coronavirus-related withdrawals....more

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