DOL Issues RFI on SECURE 2.0 Reporting and Disclosure; Comments Due October 10

The U.S. Department of Labor's (DOL) Employee Benefits Security Administration (EBSA) issued a Request for Information (RFI) asking for public input to begin developing a public record for a number of provisions of the SECURE 2.0 Act of 2022 (SECURE 2.0) that impact the reporting and disclosure framework of the Employee Retirement Income Security Act of 1974 (ERISA).

Several sections of SECURE 2.0 establish new, or revise existing, ERISA reporting and disclosure requirements, in some cases also requiring that DOL undertake a review of existing or new requirements and submit reports to Congress on DOL's findings. The RFI focuses on certain SECURE 2.0 sections that principally impact, directly or indirectly, ERISA’s reporting and disclosure requirements. Not all of the SECURE 2.0 provisions that affect the reporting and disclosure framework of ERISA are covered in the RFI, generally because DOL has already started or intends to initiate separate notice and comment rule making, actions, issue guidance, request additional information, or release reports, as appropriate, to implement these other provisions.

The RFI seeks input on questions related to a number of SECURE 2.0 provisions, including: