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Does the DFVCP only apply to plan years beginning on or after January 1, 1988?

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Does the DFVCP only apply to plan years beginning on or after January 1, 1988?

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A plan administrator is required to file an annual report for an employee benefit plan beginning with the 1975 plan year. However, during the DFVCP, the Department is targeting all plan years beginning on or after January 1, 1988 — the effective date of ERISA 502(c)(2).

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A plan administrator is required to file an annual report for an employee benefit plan beginning with the 1975 plan year. However, during the DFVCP, the Department is targeting all plan years beginning on or after January 1, 1988 – the effective date of ERISA 502(c)(2).

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