Things I Worry About (21): Pooled Employer Plans and DOL RFI (2)
Key Takeaways The DOL has issued guidance about PEPs—pooled employer plans—that provides tips for adopting employers and questions about PEPs and a possible fiduciary safe harbor for small employers who adopt PEPs. In addition, the preamble to the guidance includes some interesting information about the development of PEPs. That information includes data about the successes […]
Things I Worry About (11): DOL Cryptocurrency Guidance Withdrawn
Key Takeaways The Department of Labor’s Employee Benefits Security Administration (EBSA) issued Compliance Assistance Release (CAR) 2022-01 that caused concerns among plan sponsors and fiduciaries about the use of cryptocurrencies in participant directed plans. On May 28 of this year, the DOL’s EBSA rescinded that CAR. That should have the effect of reducing, but not […]
Things I Worry About (8): DOL Investigations and Unsuspecting Plan Sponsors (2)
Key Takeaways The Employee Benefit Security Administration (EBSA) of the US Department of Labor (DOL) recently released its Fact Sheet: EBSA Restores Nearly $1.4 Billion to Employee Benefit Plans, Participants, and Beneficiaries: ebsa-monetary-recoveries.pdf One of the targets of their investigation is “missing participants”. The DOL refers to that program as the “Terminated Vested Participant Benefits […]
Things I Worry About (7): DOL Investigations and Unsuspecting Plan Sponsors
Key Takeaways The Employee Benefit Security Administration (EBSA) of the US Department of Labor (DOL) recently released its Fact Sheet: EBSA Restores Nearly $1.4 Billion to Employee Benefit Plans, Participants, and Beneficiaries: ebsa-monetary-recoveries.pdf The Fact Sheet describes the different EBSA programs that can recover money for participants, and the numbers are impressive. However, the Fact […]