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DOL Finalizes PTE 84-24 Amendments

On April 25, 2024, the U.S. Department of Labor (“DOL”) published its much-anticipated final regulation on the definition of “fiduciary” under section 3(21)(a)(ii) of the Employee Retirement Income Security Act of 1974, as...more

DOL Amends Fiduciary Advice Definition Regulation 

On April 23, 2024, the U.S. Department of Labor (“DOL” or “Department”) issued a final regulatory package amending its fiduciary investment advice regulation and revising numerous existing prohibited transaction exemptions...more

DOL Finalizes PTE 2020-02 Amendments

On April 25, 2024, the U.S. Department of Labor (“DOL”) published its much-anticipated final regulation on the definition of “fiduciary” under section 3(21)(a)(ii) of the Employee Retirement Income Security Act of 1974, as...more

DOL Finalizes More Stringent Procedures for Requesting Prohibited Transaction Exemptions

The Department of Labor’s (“DOL”) prohibited transaction exemption procedures provide an opportunity for plan sponsors, service providers, industry groups, or others to apply for permission to engage in a variety of...more

New DOL Advisory Opinion Guidance Outlines Approach for Diverse Plan Investment Manager Hiring Program

In a September 29, 2023 Advisory Opinion issued to Citigroup Inc. (“Citi”), the Department of Labor (“DOL”) addressed several key ERISA implications arising in connection with a Citi Racial Equity Program (the “Program”). ...more

Plaintiffs Target Use of 401(k) Plan Forfeitures

In the past month, plaintiffs have filed two separate lawsuits – Dimou v. Thermo Fisher Scientific, Inc. and Rodriguez v. Intuit, Inc – accusing plan fiduciaries of violating the Employee Retirement Income Security Act of...more

DOL Drops Appeal in ASA Case

U.S. Department of Labor (“DOL”) has accepted a new setback to its longstanding initiative to subject IRA rollover recommendations to ERISA’s fiduciary standard and its prohibited transaction rules.  On May 15, 2023, the DOL...more

DOL Suggests Changes to Its Voluntary Fiduciary Correction Program and Related Exemption

November 18, 2022, the Department of Labor (“DOL”) released a number of changes to its Voluntary Fiduciary Correction Program (“VFCP”) in both an update of VFCP and related guidance....more

DOL Finalizes ESG, Proxy Voting Regulation

The Department of Labor (the “DOL”) recently finalized a regulation amending the rules under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), related to the selection of plan investments and the...more

Deference Declined: Fiduciary Status for Rollovers Not a Given and New Developments in Uses of Plan-Related Data Under ERISA

A September 27, 2022 decision by the Southern District of New York addresses several key theories recently advanced by the plaintiffs’ bar in ERISA-based lawsuits against plan service providers. In Carfora v. TIAA, S.D.N.Y....more

DOL (Somewhat) Unshackles Auditors from Stringent Independence Requirements

On September 6, 2022, the Department of Labor (the “Department”) published an Interpretive Bulletin entitled “Independence of Employee Benefit Plan Accountants” (the “Bulletin” or “IB 2022-01”) superseding previous guidance...more

DOL Cybersecurity Investigations: The Trap Door to Endless Document Requests?

Parties involved in a Department of Labor (“DOL”) Employee Benefits Security Administration (“EBSA”) investigation often ask a simple question: how much information am I obligated to provide the DOL in response to an...more

Division of Fiduciary Duties Proves Key to Success in Stock Drop Lawsuit

On August 1, 2022, the United States Court of Appeals for the Seventh Circuit affirmed the lower court’s dismissal of a “stock drop” lawsuit against Boeing. The Seventh Circuit based its conclusion on the fact that an...more

DOL Releases FAQs on PTE 2020-02, Foreshadows Future Activity on Investment Advice

On April 13, 2021, the Department of Labor (“DOL”) issued a set of Frequently Asked Questions (“FAQs”) on the DOL’s new class exemption for the provision of investment advice, known as Prohibited Transaction Exemption (“PTE”)...more

DOL Issues Missing Participants Guidance

On January 12, 2021, the Department of Labor (the “DOL”) issued three pieces of guidance detailing the DOL’s view of what steps plan fiduciaries should take to locate and distribute retirement benefits to missing or...more

The Race to Register: DOL Issues Final Rule on PPP Registration

On November 14, 2020, the Department of Labor (“DOL”) published the final rule “Registration Requirements for Pooled Plan Providers” (the “Final Rule”). The Final Rule describes the registration requirements for those seeking...more

DOL Shifts Focus From ESG to Pecuniary Factors in Final Rule

On October 30, 2020, the Department of Labor (“DOL”) issued its much-anticipated final rule on Financial Factors in Selecting Plan Investments (the “Final Rule”). The Final Rule amends the DOL’s long-standing “investment...more

Cybertheft Lawsuit: ERISA Fiduciary Breach Claims Dismissed Against Plan Sponsor but Move Forward Against Recordkeeper

On October 2, 2020, the Northern District of Illinois ruled on motions to dismiss in a closely-watched cybertheft lawsuit arising out of the theft of $245,000 from a participant’s account in the Abbott Laboratories Stock...more

SEC Enforcement on Common and Collective Trusts Catches Many by Surprise

On October 1, 2020, the Securities and Exchange Commission (“SEC”) made substantial waves when it published a Cease and Desist Order (“Cease and Desist Order”) regarding the Great Plains Trust Company (“GPT”) that primarily...more

DOL Proposes Rule to Crack Down on ESG

On June 23, 2020, the Department of Labor (“DOL”) issued a proposed regulation (the “Proposed Rule”) defining plan fiduciaries’ duties under the Employee Retirement Income Security Act of 1974 (“ERISA”) when considering...more

New Lawsuit Alleges Fiduciary Breaches by Plan Sponsor and Recordkeeper for Quarter Million Dollar Cybertheft

Brief Takeaway - As a result of the Coronavirus Aid, Relief, and Economic Security Act (“CARES Act”), plan sponsors and service providers across the country are bracing for a flurry of participant activity with respect to...more

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