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Which governmental activities stop (or continue) during a U.S. Government shutdown?


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Posted

Which governmental activities stop (or continue) during a U.S. Government shutdown?

 

Here’s the Labor department’s plan:

 

https://www.dol.gov/dol/Contingency_Plan.pdf

 

And here’s the Internal Revenue Service’s plan:

 

https://home.treasury.gov/system/files/266/IRS-Lapse-in-Appropriations-Contingency-Plan_Nonfiling-Season_2018-12-03.pdf

 

Other plans:

 

https://www.whitehouse.gov/omb/information-for-agencies/agency-contingency-plans/

 

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

During a “funding lapse”, EBSA staff would not work on discretionary rulemaking projects.

 

For the proposed rule on “Association Retirement Plans and Other Multiple-Employer Plans”, comments are due December 24.

 

During a shutdown, EBSA staff would not work on analyzing the comments and other steps the Administrative Procedure Act and other laws require for adopting such a rule.

 

Different practitioners have different views about whether such a delay would be a good or bad thing.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

Posted

It seems I assumed too much; Labor has an appropriation.

Treasury does not.

 

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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