Field Assistance Bulletins

Field Assistance Bulletins (or FABs) are written by the Office of Regulations and Interpretations to the Director of Enforcement and Regional Directors to provide guidance in response to questions that have arisen in field operations. FABs may also include transition enforcement relief that permits employers, plan officials, service providers and others time to respond to new laws or regulations.

2003
Document Number Subject Issue
Field Assistance Bulletin
2003-02
  • Application of Participant ContributionRequirements to Multiemployer Defined Contribution Pension Plans

In the context of a multiemployer defined contribution pension plan, to what extent may collective bargaining, employer participation and similar agreements be taken into account in determining when participant contributions can reasonably be segregated from the general assets of participating employers?

Field Assistance Bulletin
2003-01
  • Participant Loans to Corporate Directors and Officers

May a plan administrator deny participant loans to directors and executive officers of the sponsoring employer of the plan on the basis that such loans may violate Section 13(k) of the Securities Exchange Act of 1934 without contravening the requirement of section 408(b)(1) of ERISA that loans be made available to all participants on a reasonably equivalent basis?

2002
Document Number Subject Issue
Field Assistance Bulletin
2002-03
  • Disclosure and other Obligations Relating to "Float"

What does a fiduciary need to consider in evaluating the reasonableness of an agreement under which the service provider will be retaining float and what information is a service provider required to disclose to plan fiduciaries with respect to such arrangements in order to avoid engaging in a prohibited transaction?

Field Assistance Bulletin
2002-02
  • Plan Amendments Made by Multiemployer Plan Trustees

Were the trustees of two related multiemployer plans subject to ERISA's fiduciary standards when they amended the plans' trust agreement?

Field Assistance Bulletin
2002-01
  • ESOP Refinancing Transactions

What are the obligations of a fiduciary under sections 404(a) and 408(b)(3) of ERISA in connection with the refinancing of an exempt ESOP loan?