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DOL's Recent Guidance on State-Run Retirement Programs, Part II: The Interpretive Bulletin
Morgan Lewis
[Guidance Overview] Dec. 15, 2015 "What is new here is that the DOL is providing states a different standard for the establishment of an MEP than the 'employment based nexus' standard that the DOL established for private enterprises that wish to do the same. This issue is critical because MEPs can have streamlined regulatory reporting and disclosure requirements, allowing them to provide competitive cost savings to adopting employers. Another issue to watch is the DOL's query (included as a footnote in the bulletin) on whether state sovereign immunity laws need to be reviewed in light of ERISA's remedial provisions." MORE >> |
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