EBSA Electronic Distribution Rules

Today, EBSA posted all of the public comments received with respect to electronic distribution of benefit plan information. There are many great comments in this listing, including Kilpatrick's comments listed as Number 32.  Although DOL is still reviewing the comments, DOL is apparently focusing on other plan materials (such as 401k statements for example) that can be delivered electronically, rather than SPDs and SMMs.  It's unclear whether this is because DOL already has decided to adopt separate rules depending on the type of document to be transmitted.  DOL has said that proposed regulations could be issued by the end of this year.  However, more importantly, DOL also has recently said that it will issue transitional guidance in the next "few weeks" regarding the current distribution rules. We are hopeful that this guidance will be helpful to plan sponsors as they enter the busy fall enrollment season, or will otherwise be in the form of a safe harbor.    

http://www.dol.gov/ebsa/regs/cmt-1210-AB50.html

Latest Thinking

View more Insights
Insights Center
close
Loading...
Knowledge assets are defined in the study as confidential information critical to the development, performance and marketing of a company’s core business, other than personal information that would trigger notice requirements under law. For example,
The new study shows dramatic increases in threats and awareness of threats to these “crown jewels,” as well as dramatic improvements in addressing those threats by the highest performing organizations. Awareness of the risk to knowledge assets increased as more respondents acknowledged that their