WASHINGTON, October 10, 2023 – The ERISA Industry Committee (ERIC) today provided comments to the U.S. Department of Labor (DOL) in response to its Request for Information regarding implementation of notice and disclosure provisions in the SECURE 2.0 Act.
Among other issues, DOL asked stakeholders to comment on the portions of SECURE 2.0 addressing emergency savings accounts, fee disclosure mandates, new obligations to provide certain disclosures via paper, and requirements when plan participants are offered the opportunity to take retirement benefits in the form of a lump sum.
In its letter to DOL, ERIC emphasized:
- DOL should provide helpful guidance on emergency savings accounts linked to individual account plans
- Defined contribution plan fee disclosure changes should focus on clarity and flexibility
- DOL should not add requirements to new paper statement mandates
- Balanced lump sum offer disclosures should track with legal requirements
“DOL should refrain from imposing unnecessary mandates that ultimately will increase costs without enhancing the retirement security of workers and retirees,” said Andy Banducci, ERIC Senior Vice President, Retirement and Compensation Policy. “When implementing SECURE 2.0, regulators should provide helpful guidance that sticks to the parameters of the law.”
The full text of the letter from ERIC to the DOL can be found here.