Guidance on Temporary Enforcement of Participant Disclosure

The DOL has issued temporary enforcement guidance regarding the timing of the Comparative Chart required as part of the participant disclosure obligations of Labor Reg. Section ยง 2550.404a-5.

Document Excerpt

A plan administrator may furnish the “2013 comparative chart” no later than 18 months after the prior comparative chart was furnished as described below. The “2013 comparative chart” is the comparative chart that is due, according to the terms of the final regulation, “at least annually” after the first comparative chart that was furnished in compliance with the regulation. For example, if a plan administrator furnished the first comparative chart on August 25, 2012, the “2013 comparative chart” would be due no later than August 25, 2013. In accordance with this Bulletin, however, the Department will take no enforcement action based on timeliness if the plan administrator furnishes the “2013 comparative chart” by February 25, 2014.

Link http://www.dol.gov/ebsa/regs/fab2013-2.html

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