FAB 2013-02 states that the Department of Labor’s EBSA division, as an enforcement matter, will treat plan administrators as providing the disclosures that must be made annually if they furnish the “2013 comparative chart” no later than 18 months after the prior comparative chart was furnished. For those administrators who have taken steps to comply with the 2013 disclosure requirement, FAB 2013-02 states that they may furnish the “2014 comparative chart” no later than 18 months after furnishing the prior comparative chart in compliance with the regulation.
ERIC sent a letter to the EBSA on June 3, 2013 highlighting the timing issues after the first year of compliance in 2012. We asked for guidance similar to what is contained in FAB 2013-02.
A copy of FAB 2013-02 is available here.
ERIC’s comment letter is available here.
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