Under the American Rescue Plan Act of 2021 (ARPA), which was passed by Congress on March 11, 2021, the cost of health insurance coverage pursuant to the Consolidated Omnibus Budget Reconciliation Act of 1985 (“COBRA”) is...more
4/15/2021
/ American Rescue Plan Act of 2021 ,
COBRA ,
Coronavirus/COVID-19 ,
Department of Labor (DOL) ,
Employer Group Health Plans ,
Forms ,
Health Insurance ,
Model Forms ,
New Guidance ,
Notice Requirements ,
Premium Subsidies ,
Premiums ,
Relief Measures
Definitely maybe. Severance benefits are subject to ERISA if they comprise a “plan, fund or program.” The Supreme Court held that there is a plan, fund or program for severance benefits if (1) payment requires an “ongoing...more
If you’ve had better things to do, you might only be vaguely aware that the new fiduciary rule becomes effective on June 9, 2017. We’ve written about this before (here and here), but a quick refresher might be helpful as the...more
Under ERISA and the Code, a fiduciary to a plan or IRA includes a person who renders investment advice for a fee. ERISA imposes safeguards on a fiduciary by applying standards of care and duties of loyalty and penalizing a...more
6/2/2016
/ Best Interest Contract Exemptions ,
Best Interest Standard ,
Broker-Dealer ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary Duty ,
Final Rules ,
Financial Adviser ,
Financial Institutions ,
Individual Retirement Account (IRA) ,
PTEs ,
Retirement Plan ,
Service Contracts
After much controversy and criticism, the Department of Labor (DOL) issued a final conflict of interest rule on April 6th (the “Final Rule”) which expands the definition of a fiduciary for an “employee benefit plan,” as...more
4/26/2016
/ Benefit Plan Sponsors ,
Best Interest Contract Exemptions ,
Best Interest Standard ,
Conflicts of Interest ,
Department of Labor (DOL) ,
Employee Retirement Income Security Act (ERISA) ,
Fiduciary Duty ,
Final Rules ,
Individual Retirement Account (IRA) ,
Investment Adviser ,
Participant-Directed Plans ,
Personal Liability ,
PTEs ,
Retirement Plan ,
Service Agreements