Disclosing Your Thoughts on the New E-Disclosure Proposal

The Department of Labor recently released a proposed rule that would provide the ability to default participants into electronic disclosure of certain required participant documents – this week, we’d like to know what you think, and how you - and your plan sponsor clients The Department of Labor recently released a proposed rule that would provide the ability to default participants into electronic disclosure of certain required participant documents – this week, we’d like to know what you think, and how your plan sponsor clients view the proposal.

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* 1. Have you communicated with your plan sponsor clients about the proposal?

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* 2. What, if anything, has been their reaction to the proposal?

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* 3. Under the proposed rule, so long as you satisfy certain criteria, you may default participants into electronic disclosure of required participant documents, but those documents must be accessible on a website.  Do your plan sponsor clients currently maintain or utilize (though a provider) a website that enables access to plan documents?

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* 4. As noted above, under the proposed rule, so long as you satisfy certain criteria, you may default participants into electronic disclosure of required participant documents, but those documents must be accessible on a website.  Do the provider(s) you work with currently maintain/make available to their plan sponsor clients that kind of capability?

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* 5. Under the proposed rule, all participants must receive an initial paper disclosure that states they agree to receive some or all future disclosures via electronic format (the electronic notifications must provide instructions on how to opt-in to paper disclosure).  Only participants with a valid email address may be eligible for electronic disclosure.  Do these conditions seem sufficient to protect the ability of participants to receive paper disclosures, if desired?

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* 6. Under the proposed rule, a participant could elect to receive some disclosures via electronic format and some via paper format. Do you think your plan sponsor clients would prefer:

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* 7. Other comments about participant notices, electronic participant notices, the ability to opt-in (or out) of those notices, the impact of electronic versus paper notices, the interest in shifting the default disclosure type (or lack thereof), or life in general?

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* 8. What is your role working with retirement plans?

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* 9. What size plans do you PRIMARILY work with?

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* 10. Suggestions for future survey questions?  What would YOU like to ask other NAPA-Net readers?

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* 11. Depending on response rate, we might give one of the respondents to this week's poll a free registration to the NAPA 401(k) Summit, or Women in Retirement Conference.  If you'd like to be considered, please provide your email.

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