The Plan Sponsor Council of America, part of the American Retirement Association, wrote to both the Departments of Labor and Treasury with recommendations for guidance with respect to ERISA and Internal Revenue Code compliance issues that arise when there is a missing or nonresponsive retirement plan participant. (more…)
The American Retirement Association wrote to the Department of Labor objecting to language being used in recent letters to plan sponsors who reported the correction of late deposit violations outside of the Voluntary Fiduciary Correction Program (VFCP). The American Retirement Association requested that the Department immediately cease threatening that “alternative enforcement measures” may be taken...
The American Retirement Association and the Investment Company Institute wrote to the Department of Labor to highlight for the Department’s consideration a recently released 2018 update to the 2011 study, “Delivering ERISA Disclosure for Defined Contribution Plans: Why the Time Has Come to Prefer Electronic Delivery” and to request a meeting in person to review...
The American Retirement Association wrote to the Department of Labor to ask for an extension of the transition period and delay of the applicability date of the Fiduciary Regulation recommending a “tiered” approach to determine the applicability date for the delayed provisions of the Best Interest Contract Exemption, the Principal Transaction Exemption, and amendments to...
The American Retirement Association wrote to the Department of Labor to respond to the Department’s Request for Information regarding the Fiduciary Rule and Prohibited Transaction Exemptions. In the letter, the American Retirement Association recommends a delay of the January 1, 2018 applicability date for certain provisions of the Best Interest Contract Exemption, the Principal Transaction...
The American Retirement Association wrote to the Department of Labor to request interpretative guidance with respect to the obligation of a covered service provider to disclose a change in the information required to be provided under ERISA Section 408(b)(2) resulting from the June 9, 2017 applicability date for the Fiduciary Rule and related prohibited transaction...
The American Retirement Association wrote to the Department of Labor to respond to a request for comment with respect to the Conflict of Interest Regulation and related exemptions. In the letter, the American Retirement Association recommended: 1) that the definition of Level Fee in the Best Interest Contract Exemption be clarified to permit a Level...
The Plan Sponsor Council of America wrote to both the Departments of Labor and Treasury to ask for additional guidance to address the various compliance issues that arise under ERISA and the tax code when there is a missing or nonresponsive participant and to propose a ten-step sample safe harbor program to satisfy those issues....
The American Retirement Association wrote to the Department of Labor to provide comments with respect to the proposed extension of the applicability date for the Conflict of Interest Regulation and related exemptions. The American Retirement Association recommended that the applicability date be delayed until January 1, 2018 and that transitional relief with regard to the...
The American Retirement Association wrote to the Department of Labor with its overarching concern about the proposal to modernize and improve the Form 5500 series contending that the agencies developing the proposal did not adequately take into consideration the overall time and cost burden for compliance, the impact on small plan filers, and public disclosure...
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