Plan sponsors and recordkeepers have long wished for updated electronic delivery or e-delivery rules that permit electronic delivery as the default form of distribution, and one that could be applied uniformly for all notices and participant elections made under an employer benefit arrangement.
But over the years, each of the major agencies – Department of Labor (“DOL”), Internal Revenue Service (“IRS”), and Pension Benefit Guarantee Corporation (“PBGC”)—have historically had their own take on electronic delivery methods that are permissible. But with the DOL publishing its final rule in this area on May 27, 2020, we have e-delivery as the “default” method for the first time, and we move ever closer to harmonizing these rules and harnessing the power of the World Wide Web.
In the Journal of Pension Benefits article, “New DOL Safe Harbor for E-Delivery of Retirement Plan Notices,” Groom principal Elizabeth Dold and senior counsel Ellen Goodwin examine DOL electronic delivery rules that have the potential to usher the movement of retirement notices into the 21st Century.
