Electronic Delivery Guidance Under ERISA

SIFMA, as part of a Coalition of 15 trade associations, provides comments to the Employee Benefits Security Administration (EBSA) of the U.S. Department of Labor (DOL) on electronic delivery guidance under Section 404(a) of The Employee Retirement Income Security Act of 1974 (ERISA), EBSA’s Technical Release 2011-03R.  The coalition shares concerns that this interim guidance does not provide meaningful incentives or make it more feasible for employee benefit plan sponsors and their service providers to use electronic media instead of paper. With the compliance date of the participant fee disclosure rule fast approaching, the coalition also points out that the DOL’s most recently issued regulatory agenda does not include guidance on electronic disclosure.