Apologies if this has been addressed. If it has, I can't find it.
The interim final rule on lifetime income disclosures specifies that it is effective as of September 18, 2021.
However, both the rule and the original legislation state a variant of the following:
"The requirement in subparagraph (B)(iii)shall apply to pension benefit statements furnished more than 12 months after the latest of the issuance [of]... interim final rules" link
I read this to mean that the first lifetime income disclosure would need to be released at some point within 12 months of September 18, 2021 (i.e., before September 18, 2022).
That is, the first lifetime income disclosure need not be released in 2021, but must occur during 2022, most probably by the Q2/2022 statement, at the latest.
What's the community opinion?
Thanks!
