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employer specified statute of limitations


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Posted

May an employer specify its own statute of limitations regarding retirement plans on a participant or beneficiary filing a claim for benefits?

Guest Sieve
Posted

Since, I believe, the S/L for suits for benefits under ERISA is based on state law anyway, it would depend on state law as to whether the state's statutes can be limited by agreement. (For example, a limitation/reduction of the S/L on a job application has been upheld.) But, I don't think ERISA's fiduciary breach statute could be limited by agreement.

Posted

From a non-lawyer:

Since "statute of limitations" refers to a statute (that is, a law), it seems unlikely that a plan could define the law.

But, perhaps the original Q was trying to ask if the plan could define (internally) a time limit for its own appeal procedures. ERISA § 503, and the relevant DOL regulation.

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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