DOL and Treasury Update 2015-2016 Regulatory Agendas for Employee Benefits

Eversheds Sutherland (US) LLP
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The principal regulators of U.S. employee benefits have recently published updates to their guidance plans for the coming months.
  • On May 21, 2015, 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 20 pending projects related to employee benefits, which are listed in the chart below 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 July 31, 2015, the U.S. Treasury Department and the Internal Revenue Service (IRS) released their 2015-2016 Priority Guidance Plan, often informally referred to as the IRS Business Plan, which lists those issues that will be the subject of formal guidance from July 2015 through June 2016. The IRS Business Plan includes 37 pending items addressing retirement benefits and 18 pending items addressing executive compensation, health care and other benefits. They are listed on the chart below in the reverse order of when they first appeared on the agenda.

Projects added to the agendas since they were last published are shown in bold. There are 3 new DOL initiatives and 9 new tax initiatives.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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