News & Analysis as of

Plan Administrators

McGuireWoods LLP

DOL Issues Guidance Implementing SECURE Act Changes to Defined Benefit Plan Annual Funding Notices

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On April 3, 2025, the Department of Labor (DOL) issued Field Assistance Bulletin No. 2025-02 to assist defined benefit pension plan administrators with deciphering the requirements of the SECURE 2.0 Act of 2022 as to annual...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

Ogletree, Deakins, Nash, Smoak & Stewart,...

Ninth Circuit Affirms ERISA Plan Administrator’s Decision, Validates Use of Industry Guidelines and Medical Evidence

On March 5, 2019, Magistrate Judge Joseph C. Spero of the U.S. District Court for the Northern District of California issued his opinion in Wit v. United Behavioral Health, in which he attempted to significantly change how...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

You don’t have as much leverage as you think

As a plan fiduciary, I still can’t believe it. A Third Party Administrator (TPA) we terminated was trying to hold us up for valuations and a Form 5500 we paid for, as part of, annual administration. It was $80,000....more

Jackson Lewis P.C.

Missing Participants – New State Unclaimed Property Fund Option for Small Balances

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On January 14, 2025, the DOL issued Field Assistance Bulletin (FAB) 2025-01, providing sponsors and administrators of ongoing defined contribution plans with a new option for missing participant balances of $1,000 or less:...more

Shipman & Goodwin LLP

Plan Forfeiture Litigation: A Trend to Watch

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The most recent wave of ERISA litigation is focused on the use of plan forfeitures in 401(k) plans, with the newest case, Armenta v. WillScot Mobile Mini Holdings Corp. being filed just last week. Although, for years, many...more

Saul Ewing LLP

The Friday Five: Five ERISA Litigation Highlights - February 2025

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This month’s Friday Five covers an appellate ruling on a complicated case raising both state and federal claims, an instance of procedural improprieties in the administrative review process informing the court’s substantive...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Honeywell wins forfeiture case

There have been 25 cases where plan sponsors have been sued over their right to use forfeitures to reduce employer contributions. 7 cases have had motions for summary judgments made by the plan sponsors. 2 cases have survived...more

Alston & Bird

Department of Labor's Temporary Policy Allows Voluntary Escheatment of Certain Retirement Benefits

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Our Unclaimed Property and Employee Benefits & Executive Compensation teams delve into the Department of Labor’s temporary ERISA enforcement policy for unclaimed retirement benefit payments of $1,000 or less....more

Pullman & Comley - Labor, Employment and...

Retirement Plan Update – Forfeitures are New Focus of Fiduciary Breach Litigation

Many employer-sponsored defined contributions plans, including 401(k) profit sharing plans and money purchase pension plans include a vesting schedule – a period over which a plan participant earns a nonforfeitable right to...more

Epstein Becker & Green

How ERISA Litigators Strengthen Plan Compliance and Risk Management: One-on-One with Jeb Gerth

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Strategic ERISA (Employee Retirement Income Security Act) plan design and administration require more than just technical compliance—they call for foresight into how plans will hold up under legal scrutiny. In this...more

McDermott Will & Emery

Global Equity Plan Reporting Obligations for Calendar-Year 2025: Part One

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Global equity plans are complex, and administration requires collaboration between various departments, including legal, human resources, payroll, and tax. Plan administrators (and their teams) should be aware of their...more

A&O Shearman

Texas District Court ESG ruling has broader implications for ERISA plan fiduciaries

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On January 10, 2025, the U.S. District Court for the Northern District of Texas (the “Court”) held, in Spence v. American Airlines, Inc., that American Airlines (“American”) and the American Airlines Employee Benefits...more

Alston & Bird

New Year Brings New Tri-Agency FAQs About Gag Clause Prohibitions and Attestations, No Surprises Act

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Our Employee Benefits & Executive Compensation Group discusses new guidance for group health plans and insurers on complying with federal gag clause prohibitions and No Surprises Act requirements....more

Holland & Knight LLP

An Emerging Trend in ERISA Class Action Litigation: 401(k) Forfeiture Suits

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There has been a recent uptick in ERISA class actions challenging the use of 401(k) plan forfeitures. Forfeitures are employer contributions that participants forfeit when they leave employment before those contributions vest...more

Morgan Lewis - ML Benefits

Dont Forget to Invite the Committee to the Party Fiduciary Committees as Parties to a Vendor Contract

In many situations, practitioners recommend establishing a fiduciary committee to oversee ERISA-covered employee benefit plans. There are several reasons for this, including providing a well-defined process for...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Get A Grip Over Hiring An ERISA Attorney

As a lawyer, I’ve heard plenty of lawyer jokes and some of them are amusing. I once said at law school that I now know why lawyers have terrible reputations because I met some of these lawyers at law school. While lawyers...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Do what’s right for the client

As many of you know, a substantive part of my income is independent fiduciary work. Whether it’s an ERISA §3(16) administrator, trustee, or Pooled Plan Provider (PPP), my other business Austin 3(16) Fiduciary Limited, is...more

Ropes & Gray LLP

Practical Takeaways from Spence v. American Airlines, Inc. for ERISA Plan Fiduciaries

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On January 10, 2025, Judge Reed O’Connor of the Northern District of Texas issued a much-anticipated ruling in Spence v. American Airlines, Inc., which marks the first time that a federal judge has written an on-the-merits...more

Ary Rosenbaum - The Rosenbaum Law Firm P.C.

Don’t Fall For These 401(k) Plan Provider Gimmicks

A “sales gimmick” is a term that refers to a method a business employs to immediately generate demand for its product or service. I just bought Fan Fest tickets 6 months in advance because they were giving me a $30...more

Saul Ewing LLP

The Friday Five: Five ERISA Litigation Highlights - January 2025

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This month’s Friday Five explores recent decisions including the standard of review for ERISA benefit denials, whether structural conflict entitles a claimant to conflict-of-interest discovery, whether a “relative value...more

Dickinson Wright

Both Employers and Participants Benefit from New IRS Guidance on Correcting Inadvertent Benefit Overpayments

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Retirement plan administration mistakes require difficult conversations with participants, especially when the mistake involves an overpayment.  Changes in the law, specifically, SECURE 2.0 and IRS Notice 2024-77, give plan...more

Verrill

Department of Labor Launches Retirement Savings Lost and Found

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The SECURE 2.0 Act of 2022 added new Section 523 to the Employee Retirement Income Security Act of 1974 (“ERISA”), requiring the Department of Labor (the “Department”) to establish an online database called the Retirement...more

Mayer Brown

The Pensions Brief: November 2024

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ISSUES AFFECTING ALL SCHEMES - PENSIONS DASHBOARDS – UPDATED STANDARDS - The Pensions Dashboards Programme has published updated versions of: - The dashboards code of connection – This sets out how schemes and...more

Williams Mullen

Annual Employee Benefits Compliance Checklists - Plan Administrators

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Plan administrators should review the following actions to be taken before the end of 2024 and focus on what to expect for 2025. The following checklist addresses plan amendments, notices, and other considerations for...more

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