In a comment letter to the Department of Labor today, ABA expressed support for a recent proposal that would modernize retirement disclosures by facilitating the use of electronic delivery for participant notices and disclosures. ABA—which has long advocated for the use of electronic delivery—noted that the proposal would streamline document delivery to retirement savers while simplifying and improving the current disclosure regulations.
ABA recommended several changes that would help better tailor the proposal. Among other things, ABA recommended that DOL include welfare plans within the proposal, not just retirement plans; include in the proposal documents furnished upon the retirement saver’s request; and reduce the administrative burden created by the proposal’s treatment of invalid or inoperable email addresses by requiring the retirement saver to notify the plan administrator of a change in email address.
ABA’s comment letter incorporated feedback from ABA’s ERISA Attorneys Group, which includes participants from member banks of all size.
