ERISA Advisory Council to Examine Lifetime Plan Participation

The DOL’s ERISA Advisory Council at its May 27-29 meeting will include examination of lifetime plan participation. The council will focus on preparing proposed notices and disclosures related to the recommendations the council made in its 2014 report, “Issues and Considerations Surrounding Facilitating Lifetime Plan Participation.”

Among the matters the council will be examining will be the following:

Model Notices for Participants Concerning Lifetime Participation in ERISA Plans

• What information should be included in such notices?

• At what points in one’s career should notices be provided?

• If provided at multiple times in a participant’s career, should notices differ in message and content?

• In what format should notices be delivered?

• What mediums of communication should be considered beyond model notices?

• How long should notices be?

• Should notices be personalized for the individual? If so, what elements should be in the notices and what challenges does this pose from a data perspective?

• How should these notices coordinate with other required or supplemental communications that a participant receives?

Educational Materials for Sponsors on Plan Features that May Encourage Lifetime Participation

• What format should be used? FAQ? Tip sheet? Case studies? Other?

• What plan features should be highlighted?

• How should the department balance the desire to communicate innovative ideas without specifically endorsing any specific feature?

Data Security

• How is participant data secured today in the retirement system?

• What vulnerabilities should sponsors be concerned about?

• What questions should sponsors be asking their providers in this area?

Lifetime plan participation is just one of the matters the council will be discussing in its meeting. Among the others are finding solutions to plan participants’ problems understanding their choices in pension risk transfer transactions.