Testimony on Mandated Disclosures

This document is about the ineffectiveness of the Summary Plan Description (SPD) requirement and a proposal for a "Super-mini SPD" as an alternative safe harbor. The author, based on extensive experience as a plan sponsor, argues that participants generally do not read the lengthy SPDs and that alternative, concise disclosures would be more effective. The "Super-mini SPD" concept is presented as a way to increase participant engagement with plan information while reducing administrative burden on plan sponsors.