COVID-19 Update: Additional Relief from the DOL for Employers During the Pandemic Outbreak Period

May 6, 2020

On April 29, 2020, the Employee Benefit Security Administration (“EBSA”) of the Department of Labor (“DOL”) issued Disaster Relief Notice 2020-01 (“Notice 2020-01”), in response to the COVID-19 outbreak which was declared a national emergency by Presidential proclamation on March 13, 2020 (the “National Emergency”).

Notice 2020-01 generally applies to employee benefit plans, employers, labor organizations, and other plan sponsors, plan fiduciaries, participants and beneficiaries and service providers subject to the Employee Retirement Income Security Act of 1974 (“ERISA”), and provides an extension of certain deadlines for furnishing required notices, disclosures and other documents required by Title I of ERISA.

This alert provides an overview of some of the key takeaways from Notice 2020-01, including a discussion of:

  • Good Faith Delays;
  • Plan Loans and Distributions;
  • Participant Contributions and Loan Repayments;
  • Blackout Notices; and
  • General ERISA Fiduciary Compliance and Claims Processing.

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