Compliance September 29, 2014

DOL Proposes Electronic Filing of Top Hat Plan Statements

September 29, 2014 (PLANSPONSOR.com) - The U.S. Department of Labor’s (DOL) Employee Benefits Security Administration (EBSA) proposed a regulation that would require electronic filing of “top hat” plan statements, and apprenticeship and training plan notices. 
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Generally, top hat plans are pension plans for select groups of management or highly compensated employees. Under the current law, these plans, as well as apprenticeship and training plans, file paper statements and notices with EBSA. The proposed regulation would revise current filing procedures to require electronic submission of these notices and statements, but would not change current requirements for their content. 

Among other benefits, the new system provides an immediate confirmation of filing and will save time and money for filers and taxpayers. The new electronic filing system is immediately available and filers are encouraged to use it pending the adoption of a final regulation. The department will treat electronic filers as satisfying the current requirement to file paper. 

The proposed rule will be published in the September 30 edition of the Federal Register. EBSA is soliciting comments on the proposed regulation and the design of the new filing system. Comments are due 90 days from the date of publication. 

The proposed regulation can be viewed here.  

The new system for top hat plans is available here. The new system for apprenticeship and training plans is available here. 

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