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charging for VT pension plan benefit statements


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For term vested pension plan participants who receive a copy of their benefit statement at or about termination, is there some kind of minimum that the Plan Sponsor is supposed to provide them with benefit statements when asked, like say once per year or 3 years? Is it fair for their prior employer to charge them for multiple requests?

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https://www.dol.gov/sites/dolgov/files/ebsa/about-ebsa/our-activities/resource-center/publications/reporting-and-disclosure-guide-for-employee-benefit-plans.pdf

Quote

In general, at least once each quarter for individual account plans that permit participants to direct their investments; at least once each year, in the case of individual account plans that do not permit participants to direct their investments; and at least once every three years in case of defined benefit plans or, in the alternative, defined benefit plans can satisfy this requirement if at least once each year the administrator provides notice of the availability of the pension benefit statement and the ways to obtain such statement. In addition, the plan administrator of a defined benefit plan must furnish a benefit statement to a participant or beneficiary upon written request, limited to one request during any 12-month period. In addition, the plan administrator of an individual account plan must furnish a benefit statement upon request to a beneficiary that does not receive statements automatically, limited to one request during any 12-month period.

From a handy DOL site.

 

 

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I wonder how that's being interpreted.  I'm a long time VT in 2 different pension plans and neither one of them sends benefit statements.

Incidentally, why the need to send them to VT's? Unlike A's, their benefit doesn't change.

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"...upon written request..."

I'm a retirement actuary. Nothing about my comments is intended or should be construed as investment, tax, legal or accounting advice. Occasionally, but not all the time, it might be reasonable to interpret my comments as actuarial or consulting advice.

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Interesting. In my limited experience with DB plans, annual benefit statements are (or were) just sent automatically every year for all participants with a benefit, whether terminated or not. Maybe that has changed, or maybe my limited experience was with plans in the minority.

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Belgarath I have the same experience as you - even when we were required to just send them out once every three years, we did it annually.  It was done a little out of habit and a little out of realizing how if we were participating we would like to receive at least an annual update of our benefits.  And it probably prevented quite a few participants from asking "Why haven't I gotten a statement in years?  What?  Once every 3 years?  That doesn't sound right - show me where it says that."

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DB VTs may not have gotten statements in the past for whatever reason, and no one including regulators did not seem interested.  The explicit inclusion in SECURE 2.0 requiring a DB paper statement be sent at least every 3 years combined with the DOL's guidance on lost participants suggesting sending out statements helps prevent participants from going missing likely means documenting that statements were in fact sent to DB VTs will now be on agents compliance checklists.

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