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DoL Bulletin Provides Six-Month Delay on Second Round of Participant Fee...

On July 22, 2013, the Department of Labor (“DOL”) provided relief to plan administrators in the form of Field Assistance Bulletin (“FAB”) 2013-02. The FAB announces a transitional enforcement policy...

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2014 Guidance Plan Indicates a Busy Year Ahead for DOL and the NAPA...

On a semi-annual basis, the Department of Labor publishes a work plan for the guidance they intend to issue in the coming months. The plan is just that, a “plan.” There are no guarantees that the...

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‘Guide’ Must Accompany 408(b)(2) Disclosures, DOL Proposes

The Department of Labor released its long-promised proposal to require that a guide or summary accompany a covered service provider’s 408(b)2) disclosures on March 11. The final 408(b)(2) regulations,...

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Supreme Court to Hear Tibble Plan Fee Case

The U.S. Supreme Court has agreed to review the Tibble v. Edison Int’l case, it was announced Oct. 2. One of the many “excessive fee” cases being pursued through the federal court system, Tibble arose...

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Participant Benefit Statements May Be Changing

Just when plan administrators were beginning to feel comfortable with their procedures for participant benefit statements, changes are in the offing. The Department of Labor’s most recent guidance plan...

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New DOL Fiduciary Guidance Mirrors ARA/NAPA GAC’s 408(b)(2) Recommendation

The Labor Department has issued a new set of FAQs on the fiduciary regulation that embrace the recommendations made by the ARA/NAPA Government Affairs Committee (GAC) in a recent comment letter. To...

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Tax Reform Proposal Could Undermine Incentives for Small Business Plans

An outline of the Republican tax reform plan released Sept. 27 includes a proposal to cap the tax rate on small business “pass-through” income at 25%. More than 90% of businesses are organized as...

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ARA’s Advocacy Efforts Pay Off – Forfeitures May Be Used to Fund QNECs and QMACs

In a development sure to be appreciated by plan sponsors, the IRS has released final regulations allowing for the use of forfeitures to fund safe harbor contributions, specifically QNECs and QMACs. The...

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