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Increased Penalties and Faster Enforcement Potential Changes to the DOLs Form 5500 Penalty Program

Recently, we have become aware of what appears to be a new approach in the US Department of Labor’s (DOL’s) Form 5500 Annual Report (Form 5500) penalty program, including increased penalties and faster enforcement actions....more

DOL Reiterates Its Focus on Cybersecurity with Updated Guidance

The US Department of Labor (DOL) issued a press release on September 6, 2024 reminding ERISA plan fiduciaries that it considers cybersecurity to be an area of “great concern” and emphasizing that it continues to investigate...more

DOL QPAM Notification Deadline of September 15 Fast Approaching

The amendments to the QPAM Exemption include a September 15, 2024 notification deadline that will apply to many asset managers. This blog post includes a brief summary of the US Department of Labor’s (DOL’s) recent technical...more

DOL Publishes QPAM Exemption Amendments: Action Items and Considerations for QPAMS, Plan Sponsors

The US Department of Labor (DOL) published final amendments to Prohibited Transaction Class Exemption 84-14, the so-called “QPAM Exemption,” in the Federal Register on April 3, 2024. The amendments are anticipated to affect...more

2024 DOL ERISA Investigation Update: Recent Publications Offer Insight Into Possible Areas of Focus

The US Department of Labor (DOL) maintains a robust investigatory program for auditing employee benefit plans for potential ERISA violations. Under the Biden administration, the DOL’s ERISA enforcement activities and...more

ESG Investing: The US Regulatory Perspective

As companies increasingly encounter dialogue regarding environmental, social, and governance (ESG) factors, they and their investors and other stakeholders face the task of navigating the sometimes-contradictory web of...more

DOL Provides Guidance on Racial Equity Plan Supplier Program

The US Department of Labor (DOL) recently issued DOL Advisory Opinion 2023-01A, (Advisory Opinion) addressing racial equity and supplier diversity. The Advisory Opinion answered an inquiry about the application of ERISA’s...more

Reminder: DOL’s Final Rule on Prudence and Loyalty in Selecting Plan Investment Options Effective Dec 1

As discussed in a previous LawFlash, the US Department of Labor’s Final Rule on Prudence and Loyalty in Selecting Plan Investment Options, also known as the ESG Rule, contains provisions on proxy voting, which are not limited...more

Insurers: New DOL Investigatory Initiative Focuses on Evidence of Insurability Delays

A recent news release indicates that the US Department of Labor (DOL) has an investigatory initiative focused on the issue of “insurability” under life insurance benefits. This issue arises when insurance premiums are...more

ERISA Cybersecurity Compliance: SEC Proposed Rule May Provide Metrics for Evaluating Certain SEC-Regulated Plan Service Providers

In 2021, the US Department of Labor (DOL) issued cybersecurity guidance (the DOL Guidance) that sets out the DOL’s views on what processes fiduciaries of benefit plans regulated by the Employee Retirement Income Security Act...more

ESG Rule Challenged in Congress and Courts

Both the US House of Representatives and the Senate passed a resolution to overturn the US Department of Labor’s so-called “ESG Rule” on February 28 and March 1, 2023, respectively. The ESG Rule has been a topic of debate as...more

DOL Continues Active ERISA Enforcement and Focus on Cybersecurity Including Health and Welfare Plans

The Employee Benefits Security Administration (EBSA) of the US Department of Labor (DOL) has continued to be active in civil and criminal enforcement investigations of ERISA’s fiduciary duties. This blog post details two...more

DOL Reframes ESG Investing and Proxy Voting for ERISA Fiduciaries

The US Department of Labor released a final rule reframing how ERISA-regulated fiduciaries can consider environmental, social, and governance factors in retirement plan investment decision making....more

US Department of Labor Gives a Green Thumbs Up to ESG

The US Department of Labor (DOL) released the Final ESG Rule on November 22, 2022, regulating the consideration of environmental, social, and governance (ESG) factors by fiduciaries of employee benefit plans subject to the...more

The Interplay Between ESG Investing and ERISA’s Fiduciary Duties

Environmental, social, and governance (ESG) investing—especially the “E”—is an increasingly hot topic for investors, but it presents unique legal issues for retirement plan decision makers who have strict fiduciary duties to...more

State Anti-ESG Bills May Complicate Public Retirement Plan Investing

At the same time that the federal government, through the US Department of Labor, appears to be easing retirement plan fiduciaries’ paths to considering certain environmental, social, or governance (ESG) factors in making...more

US Department of Labor Proposes Extensive Changes to QPAM Exemption

The US Department of Labor (DOL) published in the July 27, 2022, Federal Register a number of proposed changes to Prohibited Transaction Class Exemption (PTE) 84-14, the so-called “QPAM Exemption.” Investment managers of US...more

Retirement Plans: A Battleground for Socially Conscious Investing Efforts?

As the US Department of Labor (DOL) continues to contemplate the role of environmental, social, and governance (ESG) considerations in ERISA plan investing, ESG issues surrounding retirement plans are cropping up in another...more

DOL Seeks Input on Climate Change’s Impact on Retirement Security

The US Department of Labor (DOL) recently announced that it is seeking comment on the impact of climate change on retirement security and what actions, if any, the agency should take to protect retirement savings from such...more

EBSA Enforcement Statistics for FY 2021: Growing Focus on Service Providers, Health & Welfare Plans

At the end of each fiscal year, the US Department of Labor’s (DOL’s) Employee Benefits Security Administration (EBSA) compiles the monetary results it obtained through various initiatives meant to ensure compliance with the...more

ERISA Fiduciaries: DOL Proposed Rule Signals More Ease for ESG Investing

The US Department of Labor on October 14 published in the Federal Register a “Notice of Proposed Rulemaking on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights.” The proposed rule, if...more

DOL Proposed Rule on Consideration of ESG Factors in ERISA Plan Investing: Proxy Voting Edition

The US Department of Labor (DOL) released on Wednesday, October 13, a Notice of Proposed Rulemaking on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (the proposed rule), which would...more

Regulatory Ping Pong: DOL Releases Proposed Rule on Considering ESG Factors in ERISA Plan Investing

The Department of Labor (DOL) released on October 13, 2021, a Notice of Proposed Rulemaking on Prudence and Loyalty in Selecting Plan Investments and Exercising Shareholder Rights (Proposed Rule), which would amend a prior...more

Department of Labor Teases Cryptocurrency Interest

Hinting that the US Department of Labor (DOL) is currently working on guidance related to cryptocurrency, the Acting Assistant Secretary for the DOL’s Employee Benefits Security Administration recently commented that the DOL...more

Target Date Funds: Facing Increasing Congressional, Regulatory, and Legal Scrutiny

In recent years, target retirement date funds (TDFs) have become a very popular investment option on participant-directed defined contribution plan investment lineups. But, as discussed in this LawFlash, as TDFs have grown in...more

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