DoL Issues New Guidance on Appropriate Plan Expenses (from Lockton)

On  April  2,  2012,  the Department of Labor (DoL) issued Field Assistance Bulletin providing guidance on appropriate plan expenses in the context of apprenticeship and   training plans.  These plans have unique characteristics not present in most welfare and   pension plans however; the Bulletin provides insight into the DoL’s views regarding the   permissibility of certain types of plan expenses to be paid by any ERISA plan. According  to the DoL:

  • Payments to promote, advertise or market a plan would, “except in rare circumstances” not be permissible.
  • Any  expense  paid  from  plan  assets  must  be  justified  as “appropriate and helpful to the  plan  obtaining  the  service  in  carrying  out  the  purposes  for  which  the  plan  is established or maintained.
  • Using  plan  assets  to  buy  tickets  to  sporting  events  and  other  entertainment  events   for  plan  participants,  employers  or  fiduciaries  is  not  permitted.
  • The plan may not make donations to fiduciaries’ or officials’ favored charities or causes.

More from Lockton >> April 30 2012 Appropriate Plan Expenses

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About thebenefitblog

Eric is a Producer at Lockton Insurance Brokers, Inc., the world’s largest privately held commercial broker. Eric has over 23 years of experience in the insurance industry and has spent the last 11 years with Lockton. Eric specializes in Health & Welfare Benefits, Retirement Planning, and Executive Benefits. Eric's clients utilize his expertise in the areas of Plan Due Diligence, Transaction Structure, Fiduciary Oversight, Investment Design, Compliance and Vendor negotiation to improve the operational & financial outcome for each client. The Benefit Blog is a place to share that expertise and industry news.
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