Information Letters

Requests for interpretations and other rulings under Title 1 of ERISA are handled by the Office of Regulations and Interpretations under the provisions established by ERISA Procedure 76-1. The office answers inquiries from individuals and organizations in the form of information letters, which call attention to well established principles or interpretations.

2016
Date Recipient Description of Request
Information Letter
2016-12-22

Mr. Christopher Spence
Senior Director, Federal Government Relations, TIAA
601 Thirteenth Street, NW
Suite 700 North
Washington, DC 20005

Application of ERISA's fiduciary provisions to default investments with lifetime income features that contain certain liquidity and transferability restrictions.

2014
Date Recipient Description of Request
Information Letter
2014-12-15

J. Mark Iwry
Senior Advisor to the Secretary and Deputy Assistant Secretary
for Retirement and Health Policy
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

Guidance on whether retirement savings accounts established under the U.S. Department of the Treasury's retirement security program (also known as myRA) would be covered under Title I of ERISA.

Information Letter
2014-10-23

J. Mark Iwry
Senior Advisor to the Secretary and Deputy Assistant Secretary
for Retirement and Health Policy
Department of the Treasury
500 Pennsylvania Avenue, NW, Room 3044
Washington, DC 20220

Guidance under 29 CFR 2550.404c-5 and 2550.404a-4 with respect to a series of target date funds that seek to provide lifetime income through the use of unallocated deferred annuity contracts.

2012
Date Recipient Description of Request
Information Letter
2012-11-09

Susan M. Camillo, Esq.
Dechert LLP
200 Clarendon Street
27th Floor
Boston, MA 02116-5021

Guidance as to the definition of "related" in PTE 84-14, the QPAM class exemption.

2010
Date Recipient Description of Request
Information Letter
2010-07-12

Charles V. Stewart
Akin Gump Strauss Hauer & Feld LLP
1333 New Hampshire Ave., N.W.
Washington, DC 20036-1564

Whether, in the context of a collectively bargained multiemployer plan, plan expenses paid by a contributing employer and not reimbursed by the plan are required to be reported on the Schedule C (Service Provider Information) of the Form 5500 Annual Return/Report of Employee Benefit Plan (Form 5500).