News & Analysis as of

Benefit Plan Sponsors

Bricker Graydon LLP

What If an Employee Doesn’t Tell You They Got Divorced?

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When an employee forgets—or chooses not—to notify you of a divorce, it can cause a ripple effect on your benefit plan administration, particularly with your health plan. Here's what you need to know and do to keep your health...more

Husch Blackwell LLP

Supreme Court Decision Means Defense of ERISA Prohibited Transaction Claims Just Got More Difficult and More Protracted

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On April 17, 2025, the Supreme Court decided Cunningham v. Cornell University, unanimously holding that a plaintiff can state a valid claim under ERISA by merely alleging that a plan used “plan assets” to pay a service...more

Nelson Mullins Riley & Scarborough LLP

DOL Issues Late-Breaking Guidance on Defined Benefit Pension Plan Annual Funding Notices

The SECURE Act 2.0, enacted in December 2022, made several updates to what must be included in annual funding notices (“AFN”) issued by defined benefit pension plans. For large plans (as defined below) with a plan year ending...more

Vedder Price

Cunningham v. Cornell University

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On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion on the requirements for plaintiffs to survive a motion to dismiss regarding an allegation that plan fiduciaries engaged in a prohibited transaction under...more

Alston & Bird

IRS Proposes Changes to 401(k) Catch-Up Contributions

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Our Employee Benefits & Executive Compensation Group discusses what plan sponsors and fiduciaries need to know about the Internal Revenue Service’s proposed changes for employees 50 or older who make additional elective...more

Miller Canfield

ERISA in the Supreme Court: Implications of Cunningham v Cornell University

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On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion in Cunningham v Cornell University, addressing the pleading standard applicable to prohibited transaction claims under the Employee Retirement Income...more

Venable LLP

Supreme Court Endorses Plaintiff-Friendly Prohibited Transaction Pleading Standard

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On April 17, 2025, the Supreme Court resolved a circuit split on the appropriate pleading standard for a specific type of prohibited transaction claim under ERISA. While that decision may sound dry and technical, the...more

Kilpatrick

The Supreme Court Delivers Troubling Decision for ERISA Excess Fee Cases

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On April 17, 2025, the U.S. Supreme Court issued a unanimous opinion that has the potential to make it more difficult for defendants to have excess fee cases for 401(k) or 403(b) plans dismissed at an early stage of...more

Goodwin

Supreme Court Decides Pleading Standard to Allege ERISA Prohibited-Transaction Claims, Favoring Plaintiffs

Goodwin on

Key takeaway: The Supreme Court held that to state an ERISA prohibited-transaction claim under 29 U.S.C. § 1106(a), a plaintiff needs only to plausibly allege the elements contained in § 1106(a) itself and does not need to...more

Kaufman & Canoles

ESOPs Benefits & Compensation - Q1 2025 Client Alert

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Happy Spring from the Kaufman & Canoles ESOPs, Benefits & Compensation team! We hope you’re shaking off the winter blues and ready for another round of benefits updates. ...more

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Cunningham v. Cornell University

On April 17, 2025, the Supreme Court decided Cunningham v. Cornell University, No. 23-1007, holding that a plaintiff may state a prohibited-transaction claim in violation of ERISA § 406(a) without referencing the exemptions...more

Seyfarth Shaw LLP

Supreme Court Lowers Bar to Pleading Prohibited Transactions, Despite “Serious Concerns” of Meritless Litigation

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In a unanimous decision reversing dismissal of prohibited transaction claims based on fees paid to defined contribution plan recordkeepers, the Supreme Court held that ERISA’s prohibited transaction exemptions are affirmative...more

Bricker Graydon LLP

More Discretion, More Documentation: Recovering Overpayments Under Secure 2.0

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Under SECURE 2.0, plan sponsors were granted discretion to determine whether or not the plan would recoup "inadvertent benefit overpayments." However, SECURE 2.0, did not define the term, leaving implementation of the new...more

Lathrop GPM

Call for Additional Regulations for Health Plan Compensation Disclosures

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In an April 15 Executive Order, entitled “Lowering Drug Prices by Once Again Putting Americans First,” the Trump Administration has called attention to an ERISA disclosure required by the Consolidated Appropriations Act of...more

Smith Anderson

New DOL Guidance for Pension Plan Sponsors - What Employers Need to Know

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On April 3, 2025, the U.S. Department of Labor (DOL) issued important new guidance for employers that sponsor defined benefit (pension) plans. This guidance provides new model notices and addresses several outstanding...more

Verrill

Does ERISA Work?

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On Labor Day, September 2, 1974, Gerald Ford signed the Employee Retirement Income Security Act (“ERISA”) into law. ERISA governs the employee benefit plans (i.e., retirement and welfare plans) of most private employers in...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Be Choosy When Picking Your 401(k) Plan’s TPA

I was very lucky that when I started as an ERISA attorney in 1998, I worked as a staff attorney for a third-party administrator (TPA). It gave me insight and experience that I could never have gotten as an attorney working...more

Foster Swift Collins & Smith

Navigating Long-Term Part-Time Employee Eligibility Rules for 401(k) Plans

The landscape of retirement plan eligibility is shifting, and plan sponsors need to prepare for key compliance changes affecting long-term part-time (“LTPT”) employees. These new rules, mandated by the SECURE Act of 2019 and...more

Holland & Knight LLP

Excessive Fee Cases: Not Just for Retirement Plans Anymore

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A recent wave of cases has attempted to apply the theory of liability for retirement plan excessive fee cases to health plans – specifically, arrangements with pharmacy benefit managers. Though the cases thus far have...more

Bricker Graydon LLP

The DOL Lost and Found Database is Live

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Late last year, the Department of Labor (DOL) launched the public Retirement Savings Lost and Found Database. Created as part of SECURE 2.0, the DOL hopes that the database will serve as a centralized location to help missing...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Providing Info to Participants

ERISA requires disclosure of certain plan documents to participants including a summary plan description, statements, and notices. The problem is what do you do with people who aren’t participants such as potential employees?...more

Bricker Graydon LLP

Why You Can’t Kick High Claimants Off Your Health Insurance

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If your health insurance premiums have gone up again, you are not alone.  For that reason, we frequently get questions from clients on whether there is anything they can do to get high claimants off of their plans....more

Morris, Manning & Martin, LLP

EBSA Guidance on Annual Funding Notices … Better Later than Never

On April 3rd, the Employee Benefits Security Administration (EBSA) released FAB 2025-02 and related model notices to provide some guidance for the 2024 plan year annual funding notices (AFNs). The EBSA is requiring that plan...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Cheats Sheets And Hacks For 401(k) Plan Sponsors

One of the greatest advancements in my lifetime has been the proliferation of the Internet. While the web has been the greatest distracting tool in my life, it’s full of information. Anything I’ve ever wanted to know about...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Managed Accounts have room to grow

Sponsors of 401(k) plans are increasingly recognizing the need to provide personalized investment options for their participants; however, access to managed accounts still remains limited....more

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