By Seth Gaudreau and Stephen Wilkes On June 8, 2023, the Securities and Exchange Commission’s (“SEC”) Division of Examinations (the “Division”) published a risk alert (the “Risk Alert” - found here)...
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Law Alert | Stephen Wilkes
SEC Issues New Guidance For Investment Advice Obligations
By Stephen Wilkes and Seth Gaudreau On April 26, 2023, the U.S. Securities and Exchange Commission (“SEC”) published a Staff Bulletin (the “Bulletin”) reiterating the care obligation standards of...
DOL Rule Permits Consideration of Climate and ESG Factors and Codifies Proxy Voting Responsibilities
By Stephen Wilkes, Izzy Goldowitz and John Sohn On November 22, 2022, the Department of Labor (“DOL”) issued a final rule modernizing and revising the long-standing Investment Duties Regulation....
IRS Publishes Registered Apprenticeship Guidance
By Stephen Wilkes and Seth Gaudreau On November 30, 2022, the Internal Revenue Service (“IRS”) and the Department of the Treasury (“Treasury”) published Notice 2022-61 (the “Notice”) in the Federal...
DOL “Clarifies” Guidance on the Bonding Requirements to PEPS and Their Pooled Plan Providers
By Stephen Wilkes, Seth Gaudreau and Susan Rees A recent Information Letter from Eric Berger, Chief, Division of Coverage, Reporting and Disclosure, in the Office of Regulations and Interpretations...
Department of Labor (“DOL”) Proposes to “Update” QPAM Exemption
One of the most frequently used of the prohibited transaction class exemptions is Prohibited Transaction Class Exemption 84-14, which provides an exemption for Qualified Plan Asset Managers (the...
ERISA World Awaits Next EBSA Move on Proposed Restrictions on the Prohibited Transaction Exemptions Process
It has been almost four months since the Employee Benefit Security Administration (EBSA) of the Department of Labor (“DOL”) published its proposed amendments to regulations for the procedures by...
DOL “Clarifies” Guidance on Private Equity Investments In Defined Contribution Plans
It has been a frequently stated observation that the policy position of the Department of Labor (“DOL”) on pension issues may vary a bit with the party occupying the White House. A recently issued...