What Conditions Does the DOL Impose on the Transition Relief?
It is important to note that the DOL’s annual reporting exemption is conditional. Further, a plan sponsor must ensure compliance with the following four requirements for each pre-2009 annuity contract it elects to exclude from the reporting requirements for each applicable year: • Pre-2009 Annuity Contract: Exempted annuity contracts must have been issued to a current or former employee prior to January 1, 2009. • No Current Employer Contributions: The employer must have ceased any obligation to make contributions (including employee salary reduction contributions) to the annuity contract, and must have ceased making any such contributions to the annuity contract prior to January 1, 2009. • Participant Control: All rights and benefits under the annuity contract must be legally enforceable against the insurer or custodian by the individual owner of the annuity without any involvement by the employer. • Fully Vested: The individual owner of the annuity contract must be fully vested. To t
Related Questions
- With the GAO report, congressional hearings, the DOL 408 project and class action suits on revenue sharing with mutual funds, what advantage do ETFs have?
- Has the DOL issued transition relief allowing exclusion of past employees as part of the definition of "participants?
- What Conditions Does the DOL Impose on the Transition Relief?
