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This Week From the Hill (January 12 – 18, 2025)

Each week while Congress is in session, our Policy team delivers a key update to highlight a topical benefits, health, or retirement news item from the Hill, such as a newly introduced bill, a summary of a committee hearing,...more

2024 Fiduciary Rule – Impact on HSAs and Health & Welfare Plans

The Department of Labor (“DOL”) recently released a final regulation (the “Fiduciary Rule”) redefining “investment advice” under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) and section 4975 of...more

Is Your DC Plan Retirement Ready?

Participating in DC plans such as 401(k), 457, and 403(b) plans is the primary way most people save for retirement, and there is considerable sponsor and participant interest in making DC plans more effective at their primary...more

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

Amendment to QPAM Exemption

On April 2, 2024, the Department of Labor (“DOL” or “Department”) released an amendment (the “Amendment”) to Prohibited Transaction Exemption 84-14 (the “QPAM Exemption” or “Exemption”). The changes were proposed by DOL in...more

New Guidance on Pension-Linked Emergency Savings Accounts

Over the past several years, there has been a growing interest in enhancing employee benefit programs to help employees save for emergencies. Employers and service providers have developed a number of different types of...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 Seeks Input on SECURE 2.0 Changes

On August 11, 2023, the Department of Labor (“DOL”) issued a Request for Information (“RFI”) asking for stakeholder input on a number of regulatory issues related to the SECURE 2.0 Act. The wide-ranging RFI seeks feedback on...more

PBGC Update: 4010 Reporting Waivers & Benefit Payment Regulations

The Pension Benefit Guaranty Corporation (“PBGC”) recently issued Technical Update Number 23-1 to provide for certain underfunded pension plans a limited waiver from the reporting requirements under ERISA section 4010 due to...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

PBGC Issues Proposed Regulation for Multiemployer Plan Withdrawal Liability Assumptions

On October 14, 2022 the Pension Benefit Guaranty Corporation (“PBGC”) published a proposed regulation regarding the interest rates that multiemployer pension plan actuaries use when calculating the present value of plans’...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 Proposes Amending QPAM Exemption

The Department of Labor (“DOL”) recently proposed an amendment (the “Proposed Amendment”) to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”). The Proposed Amendment would...more

DOL Proposes to Significantly Tighten Prohibited Transaction Exemption Procedures

Over the decades since the enactment of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), many plan sponsors, service providers, and industry groups have applied for, and been granted, prohibited...more

DOL Issues Supplemental Guidance on DC Plan Private Equity Investments

On December 21, 2021, the Department of Labor (“DOL”) issued a statement concerning the investment in private equity by ERISA-covered defined contribution plans (the “Statement,” available here). The Statement is intended to...more

DOL Proposes Rule Encouraging ESG & Proxy Voting, Reducing Documentation Requirements

On October 14, 2021, the Department of Labor (the “DOL”) published a proposed regulation, “Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights” (86 Fed. Reg. 57272, the “Proposed Rule”). The...more

Courts Giving DOL More Time to Claim ERISA Violations

The Department of Labor (“DOL”) is relying on a recent Supreme Court decision to effectively extend the amount of time the agency has to bring fiduciary breach claims. DOL investigations often last years, so it is common for...more

Agencies Propose Extensive Form 5500 Amendments

The Department of Labor (“DOL”), Department of the Treasury (the “Treasury”), and Pension Benefit Guaranty Corporation (“PBGC”) (collectively, the “Agencies”) recently released a notice of proposed revisions to the Form 5500...more

House Budget Reconciliation Text Includes Significant Health, Paid Leave, and Retirement Provisions

On September 15, the House Ways and Means and Energy and Commerce Committees advanced components of the Democrats’ $3.5 trillion budget reconciliation package (“Budget Legislation” or “the Legislation”). The Legislation...more

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

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