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Examining Top Hat Plan Participation and Reporting (PDF)
Advisory Council on Employee Welfare and Pension Benefit Plans, Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]Link to more items from this source
Jan. 18, 2021

64 pages. "[T]he Council recommends that the Department: [1] Require that top hat plan sponsors notify eligible participants of the risks associated with the absence of ERISA's substantive protections ... [2] Revise the alternative reporting regime for top hat plans to: Require reporting every 3 years or, if earlier, upon ceasing to cover any employees; [and] Include, at a minimum, [specified] data elements ... [3] Issue a Request for Information seeking comments from interested stakeholders on possible regulatory definitions of a 'select group of management or highly compensated employees,' including possible bright-line definitions and/or safe harbor/unsafe harbor definitions."

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