New DOL Proposed Regulations Require Additional Disclosures for QDIAs and Target Date Retirement Funds
By Eric R. Keller, Stephen H. Harris, Joshua H. Sternoff & Matthew E. Nadworny
Two weeks ago, the Department of Labor (DOL) issued proposed regulations that, if finalized, would require plan fiduciaries of defined contribution plans with participant-directed investments to provide additional disclosures to an estimated 43.6 million participants regarding target date retirement or similar funds that are designated investment alternatives. The regulations also would expand the type of information that must be furnished to participants for qualified default investment alternatives (QDIAs), particularly QDIAs that are target date funds.
Part I of this Client Alert provides historical background regarding target date retirement funds and why the DOL believes additional rulemaking in this area is necessary, part II provides an overview of the proposed regulations requirements and compares them to similar proposed regulations issued by the Securities and Exchange Commission (SEC), and part III recommends actions plan fiduciaries should take now in light of the proposed regulations.