Pension & Benefits News EBSA issues final regs on electronic filing of top-hat plan statements, apprenticeship and training plan notices
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Wednesday, July 17, 2019

EBSA issues final regs on electronic filing of top-hat plan statements, apprenticeship and training plan notices

By Pension and Benefits Editorial Staff

The Employee Benefits Security Administration (EBSA) has issued final regulations that require electronic filing of “top-hat” plan statements, and apprenticeship and training plan notices. The final regulations are effective August 16, 2019.

Web-based filing. The final regulations revise ERISA Reg. §2520.104-22(c) and ERISA Reg. §2520.104-23(c) to require internet-based electronic filing of apprenticeship and training plan notices and top-hat plan statements with the Labor Department through EBSA’s website. Once they are filed, these notices and statements will be posted on the Department’s website at http://www.dol.gov/ebsa and be available to the public. Going forward, EBSA’s web-based filing system will be the exclusive method for filing these notices and statements. Filings by mail or personal delivery will no longer be accepted.

EBSA notes that since September 30, 2014, the web-based filing system has been available for these notices and statements on a voluntary basis. EBSA has determined that about 65% of the apprenticeship and training plan notices and about 54% of the top hat plan statements have been filed electronically using the filing system.

This submission process is designed to assist administrators by ensuring that all of the information required by the regulations is included in the notice or statement before the filing can be completed through the website, according to EBSA. In addition, the process provides an electronic confirmation to the administrator that the filing has been received by EBSA. This assurance provides a benefit to apprenticeship and training plan administrators and top-hat plan administrators that is not available through the existing paper-based filing system, EBSA notes.

SOURCE:  84 FR 27952.

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