The ERISA Industry Committee Calls on Federal Regulators to Simplify Retirement Plan Reporting and Disclosure

Washington, D.C., May 22, 2024 – The ERISA Industry Committee (ERIC) today urged the Department of Labor, Department of Treasury, and the Pension Benefit Guaranty Corporation (collectively, the Agencies) to refrain from imposing unnecessary or unactionable new requirements and to consider costs and administrative burdens when formulating recommendations required by the SECURE 2.0 Act. These comments were provided in response to a “Request for Information” issued by the Agencies in connection with section 319 of the SECURE 2.0 Act.

“ERIC’s member companies spend considerable amounts of time, money, and energy to educate their tens of millions of retirement plan participants about their benefits,” said Andy Banducci, ERIC Senior Vice President, Retirement and Compensation Policy. “The Agencies should collaborate with the employer community and others to simplify the notice and disclosure requirements, making them more efficient to produce and more accessible to workers and retirees. We look forward to continuing the dialogue and encourage the Agencies to engage stakeholders in further discussions, participant focus groups, and public hearings.”

Retirement plan disclosure is intended to efficiently provide participants and beneficiaries with understandable, actionable information. Based on those principles, ERIC’s recommendations emphasize that:

  • Disclosure changes should focus on simplification and actionability.
  • The Agencies should recommend fully authorizing universal default electronic delivery.
  • Plans should not be required to track engagement with electronically-delivered documents.
  • Information reporting to the Agencies should be required only to the extent necessary for the Agencies to perform their legal responsibilities.

ERIC member companies sponsor retirement plans, including both defined benefit and defined contribution plans, which are governed by the Employee Retirement Income Security Act of 1974, as amended (ERISA). Section 319 of SECURE 2.0 requires the Agencies to review the reporting and disclosure requirements under the Tax Code and ERISA. In consultation with industry stakeholders, the Agencies are required to report to congressional committees of jurisdiction on the effectiveness of applicable reporting and disclosure requirements while making recommendations to “consolidate, simplify, standardize, and improve” these requirements. 

The full text of ERIC’s comments can be found here.


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About The ERISA Industry Committee
ERIC is a national advocacy organization that exclusively represents large employers that provide health, retirement, paid leave, and other benefits to their nationwide workforces. With member companies that are leaders in every sector of the economy, ERIC advocates on the federal, state, and local levels for policies that promote flexibility and uniformity in the administration of their employee benefit plans.