Jump to content

DOL Enforcement Relief due to Covid?

Recommended Posts


Taxpayer received DOL inquiry and IDR for its ESOP and 401k plan right before Covid. 

As I began coordinating with service providers, Covid pandemic hit. Of the almost 100+ IDR requests I had only received a handful.  The investigator provided us with an extension until end of May. 

I note the DOL Notice 2020-01 doesn't provide any relief for enforcement actions at this time. 

I may not be looking in the correct Govt website or other forms of guidance for relief.

Anyone know if the Dept of Labor will allow enforcement actions to be suspended while businesses (and my taxpayer/client) are still dealing with the pandemic?  Thoughts and comments appreciated. 

Thank you 

Link to comment
Share on other sites

I doubt the Labor department would outright suspend an investigation.


You might persuade an investigator to allow more delay in producing records.


If a requested record is one ERISA commands a plan’s administrator to keep, or that a prudent fiduciary acting with the care ERISA § 404 requires would keep, consider that revealing too much reliance on service providers might lead an investigator to think the administrator is weak.  That could result in intensifying the investigation.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania



Link to comment
Share on other sites

Create an account or sign in to comment

You need to be a member in order to leave a comment

Create an account

Sign up for a new account in our community. It's easy!

Register a new account

Sign in

Already have an account? Sign in here.

Sign In Now

  • Create New...