Alerts5.14.20

Relief Granted to Plan Sponsors and Fiduciaries During COVID-19 National Emergency

COVID

Highlights

The Department of Labor and the Treasury Department granted relief to plan sponsors and plan fiduciaries during the COVID-19 National Emergency

Strict deadlines for providing notices and disclosures and making participant contributions to qualified plans will not be enforced, subject to good faith compliance

Inability to follow plan loan and distribution terms will not result in a failure if fiduciary makes good faith efforts to comply with requirements

In all cases, plan sponsors and fiduciaries must act in good faith to take required actions related to benefit plans and correct any deficiencies as soon as practicable


In the wake of the COVID-19 National Emergency, employee benefit plan sponsors and fiduciaries were granted additional time for providing certain participant notices (including blackout notices) and disclosures, making participant contributions to a plan and authorizing and implementing plan loans and distributions. The guidance was issued by the Employee Benefit Security Administration of the Department of Labor (DOL) as part of a coordinated effort with the Department of the Treasury and the Internal Revenue Service.

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