ERISA

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DOL ADMINISTRATIVE POLICIES RELATED TO PUBLICLY SPONSORED PAYROLL-DEDUCTION IRAs
AND ERISA-COVERED PLANS

On December 20, 2016, the U.S. Department of Labor published a final rule for qualified state political subdivisions (e.g., cities, counties) that establish payroll deduction IRA savings program for workers who do not have access to workplace savings arrangements.

  1. Final rule for savings arrangements established by qualified state political subdivisions for non-governmental employees.
  2. DOL’s Fact Sheet for City or County Savings Programs for Non-Governmental Employees.
  3. All of the public comments submitted to DOL on this rulemaking can be viewed here. On September 29, 2016, the CRI submitted comments to the U.S. Department of Labor regarding its proposed rule for savings arrangements established by state political subdivisions for non-governmental employees. Click here to view the letter.

This “city” rulemaking amends the final rule for state-sponsored retirement savings published on August 30, 2016.

  1. Final rule for State Auto-IRA Programs describing a safe-harbor for state laws that require employers to facilitate enrollment in state-administered payroll deduction individual retirement accounts (IRAs).
  2. The White House Fact Sheet: Making it Easier to Save for Retirement and news release.

On November 18, 2015, Interpretive Bulletin 2015-02 “regarding certain state laws designed to expand the retirement savings options available to their private sector workers through ERISA-covered retirement plans” was issued and effective immediately.

For a summary of the issues addressed by DOL in the final state rule, the proposed “city” rule, and the Interpretive Bulletin, see Groom Law Group’s August 29, 2016 memo.

All the latest updates are on the DOL EBSA’s website.

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View the presentations below:

Additional Resources