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Disclosure Requirements Employee Benefits Department of Labor (DOL)

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Gag Clause Prohibitions

Williams Mullen on

On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt discusses prohibitive gag clauses under the Consolidated Appropriations Act (CAA). While intended to promote transparency, not all gag clauses are...more

Nelson Mullins Riley & Scarborough LLP

DOL Issues Late-Breaking Guidance on Defined Benefit Pension Plan Annual Funding Notices

The SECURE Act 2.0, enacted in December 2022, made several updates to what must be included in annual funding notices (“AFN”) issued by defined benefit pension plans. For large plans (as defined below) with a plan year ending...more

Morgan Lewis - ML Benefits

Wait a Minute, Mister Postman: DOL Issues Annual Funding Notice Guidance

The US Department of Labor (DOL) has issued new guidance in the form of Field Assistance Bulletin No. 2025-02 (FAB 2025-02) and updated model annual funding notices (AFNs) for single-employer and multiemployer pension plans....more

McGuireWoods LLP

DOL Issues Guidance Implementing SECURE Act Changes to Defined Benefit Plan Annual Funding Notices

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On April 3, 2025, the Department of Labor (DOL) issued Field Assistance Bulletin No. 2025-02 to assist defined benefit pension plan administrators with deciphering the requirements of the SECURE 2.0 Act of 2022 as to annual...more

Groom Law Group, Chartered

DOL Issues SECURE 2.0 Annual Funding Notice Guidance, Including Updated Model Notices

On April 3, 2025, the Department of Labor (“DOL”) issued Field Assistance Bulletin 2025-02 (the “Bulletin”), which provides guidance related to certain modifications made by the SECURE 2.0 Act of 2022 (“SECURE 2.0”) to the...more

Kilpatrick

DOL Issues Model Annual Funding Notices Reflecting SECURE 2.0 Changes

Kilpatrick on

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

Proskauer - Employee Benefits & Executive...

EBSA Releases Long-Awaited Update to Model Annual Funding Notices Reflecting SECURE 2.0 Changes

Following up on our recent blog post, SECURE 2.0’s Required Changes to Annual Funding Notice Become Effective in 2025, the Department of Labor released Field Assistance Bulletin 2025-02 on April 3, which addresses compliance...more

Faegre Drinker Biddle & Reath LLP

Things I Worry About (8): DOL Investigations and Unsuspecting Plan Sponsors (2)

As explained in my last post, Things I Worry About (7), the DOL’s EBSA has a number of programs that can restore benefits to plans and participants. Those include: - Civil investigations. - Criminal investigations. -...more

Schwabe, Williamson & Wyatt PC

Year-End Compliance Considerations for Employee Benefit Plans

Open enrollment is right around the corner (at least for employers that run calendar-year health benefit plans), so many employers will be updating their benefit communication plans. Though not comprehensive, the following is...more

Snell & Wilmer

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

Snell & Wilmer on

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

Proskauer - Employee Benefits & Executive...

Transparency in Coverage Rules: When Accurate Estimates for Low‑Utilization Items and Services Are Not Available

Last week, the Departments of Labor, Treasury and Health and Human Services (“the Departments”) issued an FAQ about the final Transparency in Coverage rules (“TiC Rules”). This FAQ addresses compliance with cost‑sharing...more

Snell & Wilmer

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

Snell & Wilmer on

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

Proskauer - Law and the Workplace

Illinois Legislature Passes Bill Requiring Disclosure of Pay Scales in Job Postings

On May 17, 2023, the Illinois legislature passed House Bill 3129 (the “Bill”), which amends the Illinois Equal Pay Act (820 ILCS 112, et. seq.) to require Illinois employers to include pay scale and benefits information in...more

Bass, Berry & Sims PLC

Enforcement of the Transparency in Coverage Public Disclosure Requirement Rapidly Approaching

Bass, Berry & Sims PLC on

Starting July 1, 2022, employers that maintain group health plans (plans) and health insurance issuers (issuers) will be required to disclose pricing information on a public website in the form of three machine-readable files...more

Fisher Phillips

July 1 Deadline Looming for Health Plan Transparency Rules

Fisher Phillips on

In late 2020, the Departments of Health and Human Services, Labor, and Treasury (the Departments) released Transparency in Coverage (TiC) rules that put several new compliance burdens on group health plan sponsors. The next...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

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

Foley & Lardner LLP

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

Foley & Lardner LLP on

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

Snell & Wilmer

The DOL Asks and Answers Questions About the New Welfare Plan Fee Disclosure Rules

Snell & Wilmer on

In Field Assistance Bulletin 2021-03 (12/31/21) (FAB), the Department of Labor (DOL) issued guidance and temporary enforcement policy to address the new 408(b)(2) disclosure requirements that apply to certain service...more

Seyfarth Shaw LLP

Guidance Arrives on Long-Awaited Compensation Disclosures for Group Health Plans

Seyfarth Shaw LLP on

Seyfarth Synopsis: Almost a decade after the 408(b)(2) fee disclosure requirements took effect for retirement plan service providers, Congress finally passed legislation addressing compensation disclosure rules for service...more

Husch Blackwell LLP

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

Husch Blackwell LLP on

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

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