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Trump Admin. Rolls Back Biden-Era Rules on 401(k) Plan Investments: Crypto and ESG

The Trump administration has rescinded (or signaled that it will replace) current guidance that was issued by the Biden administration’s DOL regarding (1) retirement plan investments in cryptocurrencies (and other digital...more

5 Key Takeaways | Plan Investments and Fiduciary Risk Mitigation in the Trump Era

The landscape for retirement plan investments and fiduciary risks is shifting in the early part of the second Trump Administration, both due to changes in the administration’s policies and developments in the courts....more

DOL Obtains Further Extension to Decide Whether to Fight for the Fiduciary Rule

In a motion filed on April 14, 2025, the Department of Labor requested that the 5th Circuit Court of Appeals grant it an additional 60-day delay to decide its next steps with respect to its appeals of two July 2024 decisions...more

DOL Issues Model Annual Funding Notices Reflecting SECURE 2.0 Changes

On April 3, 2025, the US Department of Labor (“DOL”) released Field Assistance Bulletin No. 2025-02 (“FAB 2025-02”), which provides guidance regarding new content requirements that apply to pension plans’ annual funding...more

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

Effective Date of DOL’s Final Investment Advice Rule and Amended PTEs Paused

Federal District Courts in the Eastern and Northern districts of Texas issued orders on July 25th July 26th, respectively, staying the effective date of the Department of Labor’s final regulation on its “fiduciary rule,”...more

The Department of Labor's Final Investment Advice Rule

On April 25, 2024, the Department of Labor (“DOL”) published in the Federal Register its final regulation on its "fiduciary rule" (the "Final Regulation") clarifying when fiduciary status under the Employee Retirement Income...more

QPAM Amendment: What Plan Fiduciaries Need to Know

The Department of Labor (“DOL”) issued the final amendment to the qualified professional asset manager (“QPAM”) prohibited transaction class exemption on April 3, 2024, with an effective date 75 days later (i.e., June 17,...more

DOL’s Latest Update to Fiduciary Rule Focuses on Relationships

On November 3, 2023, the Department of Labor (DOL) published in the Federal Register its long-awaited proposed update to its “fiduciary rule” that defines when a person becomes a fiduciary to a retirement plan subject to...more

IRS Cautions Plan Sponsors of ESOPs

As part of SECURE 2.0, Congress directed the Department of Labor to develop an employee ownership initiative to encourage and incentivize employee ownership in the companies they work for. Last month, the Department of Labor...more

Federal District Court Narrows Interpretation of Fiduciary Rollover Advice

On February 13, 2023, a federal district court in the Middle District of Florida invalidated the Department of Labor’s (“DOL”) policy as to when advice provided by a financial institution or financial professional (“adviser”)...more

SECURE 2.0 Act of 2022, as enacted Summary of Key Provisions

On December 29, 2022, President Biden signed the Secure 2.0 Act of 2022 (the “Secure 2.0 Act”) into law. The Secure Act 2.0 builds off of the Secure Act, the last major retirement plan legislation enacted at the end of 2019,...more

Legal Alert | DOL Opens ESG Door: What Does It Mean for Plan Fiduciaries? [Video]

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 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

5 Key Takeaways | Establishing Tax Qualified Retirement Plans [Video]

Kilpatrick Townsend's Sterling Perkinson and Peter Daines recently presented "Establishing Tax Qualified Retirement Plans." These are the 5 key takeaways from their presentation....more

5 Key Takeaways - Establishing Tax-Qualified Retirement Plans

Kilpatrick Townsend attorneys Sterling Perkinson and Peter Daines presented a Strafford webinar focused on the challenges and considerations facing a company in setting up tax-qualified retirement plans. The presentation also...more

Brokerage Window Fiduciary Duties in Light of DOL Cryptocurrency Guidance

The DOL’s (DOL) recent warning that it is launching a new investigative program aimed at plans that offer investments in cryptocurrency and related products, including through brokerage windows, sent shockwaves through the...more

401(k) Plan Investments: ESG, Private Equity and Cryptocurrency

Many employers desire to offer innovative investments in their 401(k) plans as a way to enhance the plan’s value, attract talent and appeal to a younger workforce. But decisions regarding investment options are subject to...more

DOL Extends Non-Enforcement Period for PTE for Investment Advice Fiduciaries

On October 25, 2021, the Department of Labor (“DOL”) released Field Assistance Bulletin 2021-02 (FAB 2021-02), which extends its non-enforcement policies regarding certain rules applicable to fiduciaries who provide...more

DOL Proposes Rules Regarding ESG Factors and Proxy Voting

One of President Biden’s first acts upon taking office was to issue an executive order requiring federal agencies to conduct a review of policies or regulations issued by the prior administration that were inconsistent with...more

DOL Clarifies Timing of Lifetime Income Disclosures in Benefit Statements

Last year the Department of Labor (DOL) issued an interim final rule regarding the SECURE Act’s lifetime income disclosures, which require benefit statements to express a participant’s account balance as a single life annuity...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

PTE 2020-02 for Investment Advice Fiduciaries: Overview and Checklist

Overview: In general, the prohibited transaction rules (in ERISA and the Tax Code) (1) prohibit fiduciaries that provide investment advice to plans subject to Title I of ERISA (including 401(k) plans, pension plans and...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

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