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Posted

So, suppose the 12/31/2021 statement was already mailed, but without the lifetime income illustration.  Can the illustration be sent now as a "stand alone" or must the EBS be re-sent with the lifetime illustration attached? I believe it is the latter -  I haven't seen anything allowing a stand-alone in this situation - wondered if I've missed anything. 

Posted

Here’s a hyperlink to the eCFR’s display of 29 C.F.R. § 2520.105-3(b) https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-C/part-2520/section-2520.105-3#p-2520.105-3(b)

While I don’t give advice to anyone, in my view it’s safer to reissue the statement and include in it the required lifetime-income illustration.

Peter Gulia PC

Fiduciary Guidance Counsel

Philadelphia, Pennsylvania

215-732-1552

Peter@FiduciaryGuidanceCounsel.com

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