DOL Guidance

DOL to Review Final Amendments to Disability Claims Regulations

The DOL announced it is reviewing the changes made to the disability claims regulations for possible amendment or delay. Document Excerpt Link https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=201704&RIN=1210-AB39

DOL Seeks Additional 18 Month Delay of Full BICE

The DOL is proposing an additional 18 month delay, until July 1, 2019, for fiduciaries to comply with the full requirements of the Best Interest Contract Exemption. Document Excerpt Link https://www.reginfo.gov/public/jsp/EO/eoDashboard.jsp

Second Set of FAQs on Fiduciary Transition Period

The DOL has issued a second set of FAQs dealing with the fiduciary conflict of interest rules during the transition period. Document Excerpt The following FAQs provide information on (1) a “fiduciary status disclosure” issue under the Department of Labor’s ERISA section 408(b)(2) service provider disclosure regulation that applies to ERISA pension plans, (2) whether […]

DOL Intends to Delay Fiduciary BICE and Other Exemptions

The DOL has notified a district court in which the fiduciary rules are being litigated that it intends to delay the applicability date of the Best Interest Contract Exemption and other exemptions issued as part of its conflict of interest regulations. Document Excerpt Extension of Transition Period and Delay of Applicability Dates From January 1, […]

DOL Issues FAQs on Conflict of Interest Regulations

The DOL has issued additional guidance on its fiduciary conflict of interest regulations in the form of Frequently Asked Questions. Document Excerpt The following FAQs provide information on (1) a “fiduciary status disclosure” issue under the Department of Labor’s ERISA section 408(b)(2) service provider disclosure regulation that applies to ERISA pension plans, (2) whether recommendations […]

FAQs on Mental Health Parity Implementation

The Agencies released this FAQ on Mental Health Parity Implementation. Document Excerpt Set out below is an additional frequently asked question (FAQ) regarding implementation of the Paul Wellstone and Pete Domenici Mental Health Parity and Addiction Equity Act of 2008 (MHPAEA), as amended by the Affordable Care Act and the 21st Century Cures Act (Cures […]

DOL’s FAQs on Conflict of Interest Regulations

The DOL releases a set of Frequently Asked Questions on its conflict of interest regulations scheduled to become applicable June 9, 2017. Document Excerpt The following FAQs provide additional information on the transition period from June 9, 2017 to January 1, 2018.1 This guidance, like the Fiduciary Rule and related exemptions, is generally limited to […]

Field Assistance Bulletin on Temporary Enforcement Policy on Fiduciary Rule

Field Assistance Bulletin 2017-02 provides the DOL’s temporary enforcement policy on the Fiduciary conflict of interest rule to become effective June 9, 2017. Document Excerpt Accordingly, during the phased implementation period ending on January 1, 2018, the Department will not pursue claims against fiduciaries who are working diligently and in good faith to comply with […]

Advisory Opinion on Multiple Employer Plan Status

The Advisory Opinion holds that, at least in form, the employer subgroup would form a valid group or association. Document Excerpt Assuming that the Consortium’s by-laws and the instruments governing the Plan and trust are adopted as described in this letter, it is the view of the Department that the participating employer members of the […]

Small Business will be allowed to Bypass the ACA Marketplace

CMS has announced that small businesses will be allowed to bypass the SHOP, the Affordable Care Act Marketplace designed for small businesses. Document Excerpt CMS will be exploring a more efficient implementation of the Federally-facilitated SHOP Marketplaces in order to promote insurance company and agent/broker participation and make it easier for small employers to offer […]

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