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Proskauer - Employee Benefits & Executive...

DOL Rescinds 2022 Guidance Cautioning Against 401(k) Plan Investments in Cryptocurrencies

On May 28, 2025, the Department of Labor (“DOL”) issued Compliance Assistance Release No. 2025-01 which rescinds the DOL’s prior Compliance Assistance Release No. 2022-1 which had warned 401(k) plan fiduciaries against adding...more

Troutman Pepper Locke

Texas Federal Court Allows an ERISA Fiduciary Challenge Against Alleged "ESG Investing" Without Any ESG Funds

Troutman Pepper Locke on

On January 10, 2025, in Spence v. American Airlines, a federal district court in Texas ruled that American Airlines (the company) and the committee overseeing its 401(k) plans (the committee) breached their duty of loyalty...more

Seyfarth Shaw LLP

Supreme Court Lowers Bar to Pleading Prohibited Transactions, Despite “Serious Concerns” of Meritless Litigation

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In a unanimous decision reversing dismissal of prohibited transaction claims based on fees paid to defined contribution plan recordkeepers, the Supreme Court held that ERISA’s prohibited transaction exemptions are affirmative...more

A&O Shearman

Texas court upholds Biden administration’s rule on ESG Investing for ERISA fiduciaries

A&O Shearman on

In a recent decision by the U.S. District Court Northern District of Texas, Judge Matthew J. Kacsmaryk ruled that the U.S. Department of Labor’s 2022 Rule (the 2022 Rule) on environmental, social, and governance (ESG)...more

Verrill

Spence v. American Airlines: A Texas Court’s View of the Duty of Loyalty under ERISA

Verrill on

Since we last discussed environmental, social, and corporate governance (“ESG”) developments in the context of ERISA retirement plans, ESG litigation has taken a rather unexpected turn. Although the plan lineup in Spence v....more

Morgan Lewis

DOL’s VFCP Final Rule Adds Limited ‘Self-Correction’ Program for Late Contributions, Participant Loan Failures

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The Employee Benefits Security Administration recently released its final rule amending and restating the Voluntary Fiduciary Correction Program, along with corresponding amendments to a related class exemption, Prohibited...more

Fenwick & West LLP

Judge Finds American Airlines Breached its Fiduciary Duty of Loyalty by Allowing Investment Manager to Prioritize ESG Goals with...

Fenwick & West LLP on

On January 10, 2025, the U.S. District Court for the Northern District of Texas found that American Airlines and its employee benefit committee (EBC) breached their fiduciary duty of loyalty under the Employee Retirement...more

Fisher Phillips

Rising ERISA Class-Action Lawsuits Over Tobacco Surcharges in Health Plans: What Employers Need to Know + 6 Steps to Stay...

Fisher Phillips on

A wave of ERISA class-action lawsuits is challenging tobacco surcharge programs in employer-sponsored health plans across the U.S. These cases center on potential fiduciary breaches, with plaintiffs arguing that surcharges...more

Foster Swift Collins & Smith

DOL Echoes Employee Benefits and Cybersecurity Best Practices

On April 14, 2021, the U.S. Department of Labor’s (“DOL”) Employee Benefits Security Administration (“EBSA”) issued its first cybersecurity best practices guidance for retirement plans. The EBSA guidance was highly...more

Fisher Phillips

Don't Forget About ERISA in Your Health Plan’s Cybersecurity Efforts: Important Reminders for Plan Fiduciaries in the Wake of...

Fisher Phillips on

Earlier this year, a cyberattack on a leading healthcare claims processing provider had an unprecedented impact on patients and healthcare providers across the country. While group health plans were not directly targeted in...more

Bond Schoeneck & King PLLC

Are You a Fiduciary? The New Definition of an Investment Advice Fiduciary

On April 25, 2024, the United States Department of Labor (USDOL) issued a final rule, the “Retirement Security Rule,” that significantly alters the definition of a “fiduciary” under the Employee Retirement Income Security Act...more

Groom Law Group, Chartered

ERISA Group Health Plans – The New Target in Fee Cases

Earlier this year, a Johnson & Johnson (“J&J”) employee brought a class action complaint (the “Complaint”) against J&J alleging fiduciary breaches under ERISA related to the prescription drug coverage under J&J’s self-funded...more

Troutman Pepper Locke

EDVA Judge Allows Pension Investment Expert to Testify in Class Action ERISA Case

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A recent decision by Senior District Judge Robert Payne on a Daubert motion in class action litigation against a pension fund offers some helpful lessons on challenging expert witnesses in the EDVA. Trauernicht v. Genworth...more

Troutman Pepper Locke

Navigating the Impact of the New Fiduciary Rule on Insurers and Producers

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On April 23, 2024, the U.S. Department of Labor (the “DoL”) released its final rule (“Fiduciary Rule”) titled Retirement Security Rule: Definition of an Investment Advice Fiduciary (an “Investment Advice Fiduciary”), which...more

Groom Law Group, Chartered

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

Hogan Lovells

Department of Labor issues final regulation on investment advice fiduciaries

Hogan Lovells on

On April 23, 2024, the Department of Labor (the “DOL”) issued a final regulation (the “Final Rule”) that describes the circumstances under which a person will be considered a fiduciary for purposes of the Employee Retirement...more

Morgan Lewis

The ESG Investing Debate: 2023 Year-end Updates

Morgan Lewis on

Environmental, social, and governance (ESG) investing has been subject to increased US state and federal regulation over the last several years, and 2023 continued that status quo. As of January 1, 2024, 20 states have...more

Goodwin

Department of Labor Finalizes Amendments to Investment Duties Regulation

Goodwin on

On December 1, 2022, the Department of Labor (DOL) released final amendments to its regulation on investment duties under Section 404(a) of ERISA. The amendments will go into effect on January 30, 2023....more

Groom Law Group, Chartered

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

Bond Schoeneck & King PLLC

DOL Expresses Extreme Concern Over Prudence of Cryptocurrency Investments in 401(k) Plans

On March 10, 2022, the United States Department of Labor (DOL) published Compliance Assistance Release No. 2022-01 (Release) addressing “cryptocurrency” investment in 401(k) retirement plans. In its Release, the DOL expressed...more

Kilpatrick

Brokerage Window Fiduciary Duties in Light of DOL Cryptocurrency Guidance

Kilpatrick on

The DOL’s (DOL) recent warning that it is launching a new investigative program aimed at plans that offer investments in cryptocurrency and related products, including through brokerage windows, sent shockwaves through the...more

Cadwalader, Wickersham & Taft LLP

DOL Warns Sponsors against Permitting Cryptocurrency-Related Investments on 401(k) Plan Investment Menus

The U.S. Department of Labor (“DOL”) last month issued Compliance Assistance Release No. 2022-1 - 401(k) Plan Investments in “Cryptocurrencies” (the “Release”) in which it strongly cautions ERISA plan fiduciaries to use...more

Jackson Lewis P.C.

Is Crypto Too Cryptic for Your 401(k) Plan?

Jackson Lewis P.C. on

It started sometime last year and, in hindsight, was inevitable. Clients with 401(k) plans and a crypto-savvy employee population began asking whether they could offer cryptocurrency as a plan investment option. In the...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

Groom Law Group, Chartered

Cybersecurity Requests Appear in DOL Audits

Plan sponsors, fiduciaries, and service providers are being asked by DOL investigators how their ERISA governed plans address cybersecurity concerns with increasing frequency. These requests may take the form of production...more

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