You will recall DOL proposed regulations issued earlier this month providing guidance and establishing a safe harbor pursuant to which a fiduciary of a pension plan subject to Title I of ERISA will be deemed to have satisfied his or her fiduciary responsibilities in connection with the automatic rollover provisions. You can access a previous post on the subject here.
Please note the following law firm publications providing analysis and discussion of the regulations as follows:
- Davis Wright Tremaine LLP: “Automatic Rollover Safe Harbor Guidance: DOL Rolls Out New Proposed Regulation.”
- Oppenheimer Wolff & Donnelly LLP: “Fiduciary Safe Harbor for Automatic Rollovers of Forced Distributions.”
- Seyfarth Shaw LLP: “Automatic Rollovers: DOL Proposes Safe Harbor.”
A good article from Cooley Godward LLP on a different subject–“Reduction or Cancellation of “Underwater” Note Results in Income to Employee.”