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Disclosure Requirements Employee Retirement Income Security Act (ERISA) Employee Benefits

Williams Mullen

[Hybrid Event] 2024 Benefits Forum: Celebrating 50 Years of ERISA - September 12th, Richmond, VA

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Join us as we commemorate ERISA’s 50th anniversary and review the past, present and future of this pivotal legislation. This hybrid event offers two options for attendance: in-person or webinar. Both options will have an...more

Carlton Fields

Expect Focus - Volume II, May 2024

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Last Lap in SEC RILA Rulemaking Critical Unresolved Issues - Congress directed the SEC to adopt a new registration statement for registered indexed annuities (RILAs) by the end of June. Several months ago, the SEC...more

Snell & Wilmer

Donning the Plan, Forgetting the Top Hat: A Common Oversight in ERISA Compliance

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When drafting a deferred compensation plan or agreement for a key employee (a “top hat plan”), the focus is almost always on the terms of the plan. In the process, many employers miss a crucial step—filing the top hat...more

Faegre Drinker Biddle & Reath LLP

The New Fiduciary Rule (22): Can Wholesalers Become Fiduciaries

The U.S. Department of Labor has released its package of proposed changes to the regulation defining fiduciary advice and to the exemptions for conflicts and compensation for investment recommendations to retirement plans,...more

Snell & Wilmer

2023 End-of-Year Plan Sponsor “To Do” Lists (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

McDermott Will & Emery

Takeaways from a Recent COBRA Notice Class Action Settlement

Recent years have seen a barrage of class action lawsuits alleging that group health plan continuation coverage election notices, required under the Consolidated Omnibus Budget Reconciliation Act (COBRA), are deficient in one...more

Dorsey & Whitney LLP

Courts Address Participant Standing to Challenge Fees and Payments Received by Group Health Plan Service Providers

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As we recently suggested, ERISA disputes over the fees and expenses charged to employer or union sponsored group health plans may well become the next wave in ERISA litigation. At minimum, the Consolidated Appropriations Act...more

Snell & Wilmer

2022 End of Year Plan Sponsor “To Do” List (Part 1) Health and Welfare

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We are pleased to present our annual End of Year Plan Sponsor “To Do” Lists. This year, we present our “To Do” Lists in four separate Employee Benefits Updates. This Part 1 covers year-end health and welfare plan issues....more

McDermott Will & Emery

Inflation and ERISA Penalties: Hand in Hand for 2022

2022 INFLATION-ADJUSTED PENALTIES ANNOUNCED BY THE DEPARTMENT OF LABOR - The Federal Civil Penalties Inflation Adjustment Act of 2015 directs the US Department of Labor (DOL) to make annual inflation adjustments to...more

Verrill

How to Shoot Yourself in the Foot with Your SPD

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Benefit plan sponsors sometimes send out Summary Plan Descriptions (SPDs) having given too little thought to the legal consequences. Two recent cases illustrate how an organization can end up in serious and costly litigation...more

Groom Law Group, Chartered

Illinois Employers: Are You Complying With the Consumer Coverage Disclosure Act?

Illinois recently enacted the Consumer Coverage Disclosure Act (the “CCDA”), which requires that Illinois employers provide a disclosure to employees regarding how the employer’s group health plan compares with the essential...more

Proskauer - Employee Benefits & Executive...

DOL Announces Temporary Enforcement Policy and Guidance to Address New Compensation Disclosure Requirements for Service Providers...

On December 30, 2021, the U.S. Department of Labor (“DOL”) issued Field Assistance Bulletin No. 2021-03 (“FAB”), announcing its temporary enforcement policy for group health plan service provider disclosures under ERISA...more

Bond Schoeneck & King PLLC

New York State Enacts Secure Choice Savings Plan

On Oct. 21, 2021, Gov. Hochul signed new legislation requiring private employers who do not sponsor a retirement plan to automatically enroll their employees into the State’s new program. The New York State Secure Choice...more

Foley & Lardner LLP

CAA Compensation Disclosures: DOL’s New FAB Confirms the Scope is Broad

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The Consolidated Appropriations Act, 2021, Public Law 116-260 (CAA) set forth new compensation disclosure requirements that apply to service providers who provide “brokerage services” or “consulting” to group health plans...more

Ballard Spahr LLP

Temporary Enforcement Policy Addresses CAA's Health Plan Service Provider Disclosure Requirements

Ballard Spahr LLP on

Summary - The U.S. Department of Labor (DOL) has issued a temporary enforcement policy to address frequently asked questions about the requirement for certain service providers to disclose direct and indirect compensation...more

McAfee & Taft

New health plan disclosure requirements should bring more transparency

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Ten years ago, the U.S. Department of Labor (DOL) published a final regulation under the Employee Retirement Income Security Act of 1974 (ERISA) that required retirement plan service providers to disclose information about...more

Husch Blackwell LLP

Federal Government Issues New ERISA Disclosure Requirements: DOL guidance triggers important responsibilities for both service...

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On December 30, 2021, the Department of Labor (DOL) issued a temporary enforcement policy and guidance regarding group health plan service provider disclosures under section 408(b)(2) of the Employee Retirement Income...more

Morgan Lewis - ML Benefits

Temporary Enforcement Policy and Guidance on ERISA Disclosure Requirements for Group Health Plan Services

The Department of Labor (Department) issued Field Assistance Bulletin No. 2021-03 (FAB) on December 30, 2021, announcing a temporary enforcement policy for group health plan service provider disclosures under ERISA Section...more

Morgan Lewis - ML Benefits

Qualified Retirement Plan Sponsors: Don't Forget About Summary Plan Descriptions

While considering year-end tasks and planning for the upcoming year, qualified plan sponsors should think about whether they need to revise and/or reissue their summary plan descriptions (SPDs) in 2022....more

Troutman Pepper

DOL Clarifies Deadlines for Lifetime Income Illustration Disclosure Requirements Which Take Effect on September 18, 2021

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Section 105 of the Employee Retirement Income Security Act of 1974, as amended (ERISA), requires administrators of defined contribution plans to provide participants with periodic pension benefit statements. Benefit...more

Groom Law Group, Chartered

DOL Clarifies Lifetime Income Disclosure Requirement

On July 26, 2021, the Department of Labor ( “DOL”) issued a brief set of Frequently Asked Questions (the “FAQs”) clarifying certain issues related to the interim final rule (the “IFR”) implementing the lifetime income...more

Robinson+Cole ERISA Claim Defense Blog

EBSA Issues Guidance On Disclosure of Phone Call Recordings

The Employee Benefits Security Administration issued Information Letter 06-14-2021 stating that 29 C.F.R. § 2560.503-1 requires plan fiduciaries to disclose, on request, recordings and/or transcripts of phone calls between...more

Genova Burns LLC

New Disclosure Requirements Service Brokers and Consultants of Group Health Plans

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Buried in the Consolidated Appropriations Act of 2021 (the “Act”), which is most known for its $2.3 trillion spending bill that combines $900 billion in stimulus relief for the COVID-19 pandemic, are important new rules...more

Dickinson Wright

Group Health Plan Transparency Disclosure Rules Finalized: What Plan Sponsors Should Know

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The Department of Labor (DOL), the Internal Revenue Service (IRS) and the Department of Health and Human Services (HHS) (collectively, Agencies) issued final regulations in November 2020 requiring non-grandfathered group...more

Proskauer - Employee Benefits & Executive...

ERISA Disclosure Requirements for Service Providers Extended to Group Health Plans

The recently enacted Consolidated Appropriations Act of 2021 (“CAA”) requires new disclosures for brokers and other consultants providing services to certain group health plans. Under the CAA, “covered service providers”...more

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