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2023 ERISA Advisory Council Issue Statement: Employee Welfare and Pension Benefit Plans Recordkeeping in the Electronic Age (PDF)
Advisory Council on Employee Welfare and Pension Benefit Plans, Employee Benefits Security Administration [EBSA], U.S. Department of Labor [DOL]
July 27, 2023 "[T]he 2023 Advisory Council will examine the implications of employee benefit plans' shift to electronic/digital recordkeeping for compliance with ERISA's record retention requirements and related matters. The Council will examine the tools and technologies used by plan administrators and third-party service providers to manage and retain plan records electronically, and will identify recent trends in electronic recordkeeping systems, potentially including the use of artificial intelligence.... The Council also intends to investigate the transfer of records when plan-level transactions occur, such as recordkeeper transitions, spin-offs, plan terminations, orphaned plans, and pension risk transfers.... The Council intends to determine if guidance would be beneficial with respect to records retention, the authenticity and reliability of the electronic records, the data security of electronic records, or other issues[.]" |
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