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Fiduciary Duty Penalties

Holland & Knight LLP

SEC Scorches New Mexico Investment Advisers for Allegedly Defrauding Elderly Clients

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The SEC on June 2, 2025, filed a complaint against David A. Nagler and New Line Capital LLC (Defendants) in the U.S. District Court for the District of New Mexico for allegedly breaching their fiduciary duties and defrauding...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Late 5500s: The Maddening Decision Not to Use the DFVCP

There are few things more maddening, more viscerally frustrating, than watching a plan sponsor or service provider steer themselves into the abyss out of sheer pride or ignorance—or worse, some toxic blend of both. But in the...more

Bricker Graydon LLP

Don’t Forget About the IRS When Correcting Delinquent Plan Contributions

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Employers that do not timely deposit participant deferrals and loan contributions to their employer sponsored retirement plans can be subject to Department of Labor (DOL) penalties for breaching their fiduciary duties....more

Williams Mullen

PODCAST: Williams Mullen's Benefits Companion - Forfeitures Under Fire

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On this episode of Williams Mullen's Benefits Companion, host Brydon DeWitt unpacks the growing legal controversy surrounding the use of forfeitures in retirement plans. With numerous lawsuits recently filed, plan sponsors...more

Holland & Knight LLP

2025 Revisions to the VFCP: Key Changes to Correction and Compliance Options

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Historically, the IRS' Employee Plans Compliance Resolution System (EPCRS) has provided employers structured options for correcting retirement plan failures. Under this framework, certain operational errors qualified for...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Tales Of The TPAs: The Good, The Bad, And The Ugly

As I have always said, the most important 401(k) plan provider you can hire is a Third-Party Administrator (TPA). That’s because a TPA does so much work, and their incompetence can lead to you getting penalized or forcing you...more

Proskauer - Employee Benefits & Executive...

New “Self-Correction” Option for Voluntary Fiduciary Correction Starts March 17, 2025

Starting March 17, 2025, the Employee Benefits Security Administration’s Voluntary Fiduciary Correction Program (“VFCP”) will have a “self-correction” option. Although the new option eliminates the need to wait for formal...more

Faegre Drinker Biddle & Reath LLP

New Self-Correction Component under the DOL’s Voluntary Fiduciary Correction Program

The Voluntary Fiduciary Correction Program (VFCP) has long been a source of reprieve to plan sponsors and fiduciaries from enforcement actions by the Department of Labor (DOL), by allowing the voluntary correction of a number...more

ArentFox Schiff

Couture Compliance? The Fashion Workers Act Imposes New Labor Protections for Industry Workers

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On December 21, 2024, New York Governor Kathy Hochul signed into law the New York State Fashion Workers Act, which imposes new regulatory obligations on fashion companies, advertising agencies, model management companies, and...more

Morrison & Foerster LLP

Sorry I’m Late: New Guidance on Late Contributions

Twenty (20!) years after it last issued guidance, the DOL’s Employee Benefits Security Administration has finally released an updated Voluntary Fiduciary Correction Program (VFCP). VFCP is a program that permits retirement...more

Foley & Lardner LLP

SEC Settlement Highlights Importance of Proper Disclosure Requirements for Private Fund Managers

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On January 10, 2025, the Securities and Exchange Commission (SEC) settled charges against two fund managers (collectively the “Fund Managers”) and their sole owner, chief executive office, chief compliance office, and founder...more

Snell & Wilmer

2024 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 SW Benefits Updates. This Part 1 covers year-end health and welfare plan issues. Parts 2,...more

Pillsbury Winthrop Shaw Pittman LLP

Important Delaware General Corporation Law Amendments Are Signed into Law amid Recent Delaware Chancery Court Decisions

The Delaware legislature adopted DGCL amendments that restore contract certainty for merger and stockholder agreements. The Delaware General Corporation Law (DGCL) now codifies the power of corporations to enter into valid...more

Foley & Lardner LLP

Five Things on the Department of Labor’s Radar for Employee Benefit Plans

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All qualified retirement plans are subject to a myriad of requirements of the Employee Retirement Income Security Act of 1974, as amended (ERISA). The United States Department of Labor (DOL) is charged with enforcing the...more

Seward & Kissel LLP

SEC Charges FinTech Investment Adviser with First Violation of the Marketing Rule and Additional Compliance Violations

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Recently, the U.S. Securities and Exchange Commission (the “SEC”) announced charges against an investment adviser (the “Adviser”) for using hypothetical performance metrics in advertisements that were misleading pursuant to...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - March 2023

The March Monthly Minute highlights new proposed deadlines for use of retirement plan forfeitures, unsuccessful efforts to overturn the final ESG rule, and ACA penalty increases for 2024. Sorry Not Sorry: Biden Vetoes...more

McDermott Will & Emery

DOL Proposes Significant Changes to VFCP Program

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On November 21, 2022, the US Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) released a proposed amendment and restatement of the Voluntary Fiduciary Correction Program (VFCP), along with a...more

Vedder Price

Investment Services Regulatory Update - February 2018

Vedder Price on

New Rules, Proposed Rules, Guidance and Alerts – SEC STAFF GUIDANCE AND ALERTS - SEC Staff Issues Guidance on Cryptocurrency-related Holdings - On January 18, 2018, the staff of the SEC’s Division of Investment...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - August 2016

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Editor's Overview - This month’s newsletter features an article on the DOL’s recently published interim final rule that increases penalties for notice and disclosure violations, which generally became effective on...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - Remember to Update Your Risk Disclosure on an Ongoing Basis - The staff of the Securities and Exchange Commission (SEC) issued guidance reminding mutual funds, exchange traded funds, and other...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - March 2016

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Editor’s Overview - This month we review the U.S. Supreme Court’s decision in Montanile v. Board of Trustees of National Elevator Industries Health Benefit Plan where the Supreme Court considered the scope of...more

Gray Reed

Employee Benefits – Do Employers Owe a 401(k) Fiduciary Duty?

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Back in July, we discussed how Jed Clampett of Mama’s Fried Pies caused his VP of marketing Elly May to suffer exorbitant taxes due to a deferred bonus that he offered.  This month, Jed finds himself again in the grease with...more

Foley & Lardner LLP

A Compilation of Enforcement and Non-Enforcement Actions

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Non-Enforcement - Form PF — What Purpose? SEC registered investment advisers with at least $150 million of assets under management in private funds are required to periodically file Form PF with the SEC. The...more

Proskauer Rose LLP

The ERISA Litigation Newsletter - August 2015

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Editor's Overview - As the summer draws to a close, this month's Newsletter previews three cases that the U.S. Supreme Court already has agreed to hear that ought to be of particular interest to ERISA plan sponsors and...more

King & Spalding

SEC Steps Up Scrutiny On Private Fund Fee Allocation Practices

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In two recent cases, the Securities and Exchange Commission (the SEC) has made clear that it has increased its focus on private funds and their allocation of fees and expenses. In the most recent, the SEC entered an order on...more

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