Nova 401(k) Associates
Compensation Strategies Group, Ltd.
Nicholas Pension Consultants
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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]
Jan. 18, 2021
64 pages. "[T]he Council recommends that the Department:  Require that top hat plan sponsors notify eligible participants of the risks associated with the absence of ERISA's substantive protections ...  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 ...  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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