"The new regulations add the following requirements to the claims and appeals process for disability benefits: [1] Claims and appeals must be decided independently and impartially, meaning that those who decide claims should not be incentivized to deny claims.... [2] Denial letters must include [certain specified items] ... [3] Before an appeal can be denied, claimants must be given notice and a fair opportunity to respond if the appeal denial is based on new or additional rationales or evidence.... [4] Claimants are not barred from suing due to failure to exhaust the plan's claims procedures where the plan itself failed to comply with its claims procedures (except for certain minor failures). [5] Retroactive rescissions of coverage are considered benefit denials that trigger the plan's appeals procedures."