DOL and Treasury Update 2014-2015 Regulatory Agendas for Employee Benefits

The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months. The updated plans are reflected in the attached chart.

  • On November 21, 2014, the U.S. Department of Labor (DOL) updated its Semi-Annual Regulatory Agenda. This publication takes the form of a Federal Register notice to comply with certain administrative requirements. The DOL’s agenda and related materials include 17 pending projects related to employee benefits, which are listed in the attached chart in order of the projected timetable for next steps. (In the ordinary course, the projected dates shown on the agenda may prove to be ambitious.)
  • On November 7, 2014, the U.S. Treasury Department and the Internal Revenue Service (IRS) released their First Quarter Update to the 2014-2015 Priority Guidance Plan, often informally referred to as the IRS Business Plan, which updates those issues that will be the subject of formal guidance from July 2014 through June 2015. The IRS Business Plan includes 34 pending items addressing retirement benefits and 20 pending items addressing executive compensation, health care and other benefits. They are listed on the chart in the reverse order of when they first appeared on the agenda.

There are three new DOL initiatives and no new tax initiatives in the latest updates.

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Eversheds Sutherland (US) LLP
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