As we noted in our prior blog post, the DOL has announced new guidance, in the form of an interim final rule, implementing the lifetime income disclosure requirement for defined contribution plans that was added to ERISA by the 2019 SECURE Act.  This guidance has since been published in the Federal Register on September 18, 2020, and will be effective one year after the date of publication, on September 18, 2021.  The DOL has requested comments on this rule, which must be received by November 17, 2020.

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Photo of James Damon James Damon

James Damon is an associate in Covington’s Washington, DC office, where he practices with the firm’s Employee Benefits and Executive Compensation Practice Group.

Photo of Julie Edmond Julie Edmond

Julie Edmond has extensive experience counseling and litigating in the employee benefits area, including traditional defined benefit, cash balance, 401(k), profit-sharing and money purchase pension plans; executive compensation and § 409A; § 403(b) plans, § 457 plans and other plans for tax-exempt organizations…

Julie Edmond has extensive experience counseling and litigating in the employee benefits area, including traditional defined benefit, cash balance, 401(k), profit-sharing and money purchase pension plans; executive compensation and § 409A; § 403(b) plans, § 457 plans and other plans for tax-exempt organizations; ESOPs; cafeteria plans; VEBAs and self-insured medical plans and other welfare plans.  Her experience includes plan selection, formulation and drafting, regulatory compliance, audits, voluntary compliance, prohibited transactions and fiduciary duty requirements, separate line of business issues, use and handling of employee benefits and benefit plans in corporate transactions, and ERISA litigation.