"[S]uggestions that the DOL or Treasury can use to develop guidance [include]: ... [1] Either the DOL or Treasury should state that plans must follow the usual claims and appeals process.... [2] Many plans impose a statute of limitations on participants, stating, for example, that claims must be brought within three years, or even as little as one year. But plans impose no such limitations on themselves. [3] Limit recoupment to a percentage of monthly benefit.... [4] Prohibition on interest.... [5] The DOL should also develop guidance as to what constitutes a hardship, such as exists with the OPM and Social Security."  MORE >>