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October 30, 2019

Retirement

PBGC Updates Maximum Monthly Guarantees for Single-Employer Plans
On October 24, 2019, the Pension Benefit Guaranty Corporation (PBGC) updated its tables showing maximum monthly guarantees for single-employer plans for various ages and payment forms. The guarantee limits for single-employer plans that fail in 2020 will be 3.65% higher than the limits that applied for 2019. The guarantee limits for multiemployer plans are not indexed and therefore have not changed.

The tables for 2020 and earlier years are available here.

DOL Releases Proposed Rule on New Electronic Disclosure for Retirement Plans
On October 23, 2019, the Department of Labor (DOL) published a proposed rule and Request for Information (RFI) on default electronic disclosure by employee pension benefit plans under ERISA. According to the DOL, the proposed rule would “allow online retirement plan disclosures to reduce printing and mail expenses for job creators and make disclosures more readily accessible and useful for America’s workers.” The DOL is proposing a new, additional safe harbor for the use of electronic media by employee pension benefit plans to furnish information to participants and beneficiaries of plans subject to ERISA. The proposal would allow plan administrators who satisfy specified conditions to provide participants and beneficiaries with a notice that certain disclosures will be made available on a website. Individuals who prefer to receive these disclosures on paper will be able to request paper copies and entirely opt out of electronic delivery. The proposed rule also contains an RFI that explores “whether and how any additional changes to ERISA’s general disclosure framework, focusing on design, delivery, and content, may be made to further improve the effectiveness of ERISA disclosures.”

Comments on the proposed rule and RFI are due by November 22, 2019.

The proposed rule is available here.

The news release is available here.

Aon Publications

Now Available: Retirement Legal Consulting & Compliance Quarterly Update
The Retirement Legal Consulting & Compliance practice is pleased to present its Quarterly Update of recent legal developments for the fourth quarter of 2019. In this issue you will find the following articles:

 

  • Building Your Pay Equity Ecosystem
  • Actuarial Equivalence Litigation—First Dismissal
  • Ninth Circuit Enforces Mandatory Arbitration of ERISA Claims
  • The Federal Government Weighs In—CalSavers Is Preempted Under ERISA
  • Withholding and Reporting Apply to Uncashed Plan Checks
  • Hardship Distributions a Little Less Hard for Plan Sponsors
  • New DOL Guidance on Reemployed Service Members
  • The Key to Successfully Changing Plan Recordkeepers
  • Implications of New FLSA Overtime Rules for Benefit Plans
  • Quarterly Roundup of Other New Developments

 

The fourth quarter 2019 issue of the Retirement Legal Consulting & Compliance Quarterly Update is available here.

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