News & Analysis as of

Recordkeeping Requirements Employee Retirement Income Security Act (ERISA)

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Quick Tips for Plan Sponsors Who Want to Stay Out of Trouble

If you’re a 401(k) plan sponsor, you don’t need to be an ERISA expert—you just need to avoid doing dumb things. Here are a few quick tips to help you stay on the right side of your fiduciary duties and keep your participants...more

Morgan Lewis

ETFs for ERISA Plans: Operational Barriers and Potential Benefits

Morgan Lewis on

Exchange-traded funds (ETFs) have gained an increasing foothold in the wealth-management investment universe, with ETF assets under management currently about half the assets under management of mutual funds. As the ETF...more

Snell & Wilmer

Five Things to Know about the DOL’s New VFCP Self-Correction Feature Taking Effect Next Week

Snell & Wilmer on

By Amberlee Lapointe On January 14, 2025, the DOL’s Employee Benefits Security Administration (“EBSA”) released updates to its Voluntary Fiduciary Correction Program (“VFCP”), along with a News Release and Fact Sheet...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

The DOL Lost and Found Database may finally eliminate that Social Security notice nonsense

We always tell plan sponsors to keep ERISA records for 7 years. In this day and age of scanning and PDFs, should mean you don’t need to throw anything out if it’s saved online. The reason I hate for plan sponsors to throw...more

Jackson Lewis P.C.

Exciting Update: Self-Correction for Delinquent Contributions Now Possible Under the DOL’s VFCP

Jackson Lewis P.C. on

On January 14, 2025, the Employee Benefits Security Administration (EBSA) within the Department of Labor (DOL) updated its Voluntary Fiduciary Compliance Program (VFCP). The VFCP allows plan officials to correct certain...more

Proskauer - Employee Benefits & Executive...

Fourth Circuit Approves Award of Estimated Delinquent Contributions

Multiemployer benefit plans generally require contributing employers to submit “remittance reports” that identify the employees that performed covered work, the type of work performed, and the amount of time worked. Plans...more

King & Spalding

What Does a Second Trump Administration Mean for the Private Funds Industry?

King & Spalding on

The incoming Trump administration will bring significant changes to regulatory policy as it relates to the asset management industry, and private funds, in particular...more

Goodwin

Supreme Court Grants Review in ERISA Class Action Challenging Plan Sponsor’s Recordkeeping Arrangement

Goodwin on

Key takeaway: The Supreme Court granted certiorari to address the pleading standards for prohibited-transaction claims under 29 U.S.C. § 1106(a). On October 4, 2024, the Supreme Court granted certiorari in Cunningham v....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

Proskauer - Employee Benefits & Executive...

Massachusetts District Court Permits 403(b) Plan Fiduciary Breach Claims to Proceed

A federal district court in Massachusetts recently denied a motion to dismiss a complaint filed by plan participants in the Cape Cod Healthcare, Inc. 403(b) plan, which alleged that the plan’s fiduciaries breached their ERISA...more

Morrison & Foerster LLP

Amendment To QPAM Exemption

The Department of Labor (DOL) recently issued a final amendment (“Final Amendment”) to Prohibited Transaction Exemption (PTE) 84-14, which is otherwise known as the “QPAM Exemption.” The QPAM Exemption is a prohibited...more

Warner Norcross + Judd

Final Fiduciary Rule — Part 3: Amendments to PTEs 84-24, 75-1, 77-4, 80-83, 83-1 and 86-128

Warner Norcross + Judd on

On April 25, 2024, the U.S. Department of Labor (DOL) released regulations redefining who is an investment advice fiduciary under the Employee Retirement Income Security Act of 1974 (ERISA) and the Internal Revenue Code...more

Keating Muething & Klekamp PLL

Benefits Monthly Minute - May 2024

The May Monthly Minute highlights litigation wins for plan fiduciaries in a 401(k) fee case and a wilderness therapy exclusion case, and also sets out the 2025 HSA, HDHP, and excepted benefit HRA COLA adjustments....more

Eversheds Sutherland (US) LLP

Dual registrant regulatory roundup - May 2024

Welcome to the Regulatory Roundup. Each month, Eversheds Sutherland Investment Services attorneys review significant regulatory developments (including notable rulemakings and guidance from securities regulators) from the...more

Proskauer - Employee Benefits & Executive...

Fifth Circuit Reverses Dismissal of 401(k) Fees Claims

The Fifth Circuit recently reversed a district court’s dismissal of claims that the fiduciaries of a 401(k) plan breached the duty of prudence under ERISA by offering participants retail share classes instead of cheaper...more

Holland & Hart - The Benefits Dial

Just Because I’m Missing, Doesn’t Mean I’m Lost: Should Plan Sponsors Provide Data for the DOL’s Missing Participant Database?

“Missing participants” have long been a thorn in the side of plan sponsors and administrators, as they are owed a retirement benefit, but are unable to be found or unresponsive to plan communications. As a partial solution,...more

Latham & Watkins LLP

Raising the Bar: DOL’s Amendment Sets Higher Standards for QPAM Qualification

Latham & Watkins LLP on

The DOL’s final amendment to the QPAM Exemption sets forth more rigorous compliance requirements and expands the circumstances of ineligibility, potentially affecting the operations and compliance procedures of investment...more

Proskauer - Employee Benefits & Executive...

Massachusetts District Court Grants Motion to Dismiss 401(k) Fiduciary Breach and Prohibited Transaction Claims

A federal district court in Massachusetts dismissed ERISA fiduciary breach and prohibited transaction claims against 401(k) plan fiduciaries, ruling that the prohibited transaction claims were time-barred and the fiduciary...more

Proskauer - Employee Benefits & Executive...

DOL Unveils Final Amendment to QPAM Exemption

On April 3, 2024, the U.S. Department of Labor (the “DOL”) published in the federal register a final amendment to Prohibited Transaction Class Exemption 84-14 (the “QPAM Exemption”) that makes considerable changes to the...more

King & Spalding

Department of Labor Finalizes Changes to QPAM Exemption

King & Spalding on

Investment managers who manage private employee benefit plan and individual retirement account (collectively, “Plan”) assets have long relied on Prohibited Transaction Class Exemption 84-14 (commonly referred to as the “QPAM...more

Proskauer - Employee Benefits & Executive...

Second Circuit Establishes Practical Pleading Requirement for Prohibited Transaction Claims Under ERISA Section 406(a)(1)(C)

The Second Circuit recently held that in order to state a claim for a prohibited transaction pursuant to ERISA section 406(a)(1)(C), it is not enough to allege that a fiduciary caused the plan to compensate a service provider...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

Holland & Knight LLP

Tenth Circuit Dismisses Claims Related to High-Cost Funds, High Recordkeeping Fees

Holland & Knight LLP on

The U.S. Court of Appeals for the Tenth Circuit issued its decision in Matney v. Barrick Gold of North America, et al. on Sept. 6, 2023, finding that participants in an employer-sponsored defined contribution retirement plan...more

Proskauer - Employee Benefits & Executive...

Ninth Circuit: Changes to a Services Agreement Require Consideration of Indirect Compensation

A recent Ninth Circuit decision has generated considerable controversy amongst employee benefits practitioners by holding that plan fiduciaries engaged in prohibited transactions when they amended the plan’s existing...more

Proskauer - Employee Benefits & Executive...

Two District Courts Reach Conflicting Holdings Over Excessive Recordkeeping Fee Claims

Two District Courts have reached conflicting decisions on the same day when ruling on substantially similar allegations that plan fiduciaries violated ERISA by paying too much for recordkeeping services, with one court...more

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