On January 19, the Department of Labor (DOL), Treasury, and the Pension Benefit Guaranty Corporation (PBGC) issued a Request for Information (RFI) on the disclosure requirements of SECURE 2.0. The agencies said they would use this input to “explore ways to make it easier for workers to understand their benefits.”

The three agencies say they are striving to balance the interests of employers and plan participants. Ideally, disclosure rules would “give workers enough information while preserving corporate liability protection,” the agencies said.

Among the questions the RFI seeks answers to are:

• Are current notice and disclosure requirements duplicative?
• Do participants understand the information provided?
• How do participants use the information provided?
• What delivery methods do plan participants prefer?
• What are the issues relative to the frequency and timing of reports?
• What are the costs of reporting?

The agencies plan to use the results of the RFI in preparing the report on notice and disclosure rules that they are required to submit to Congress by the end of 2025.

Prospects: The notice and disclosure rules applicable to retirement savings plans can be controversial. Plan sponsors say the cost of complying with the rules is significant, and there are issues relative to the usefulness and understandability of the disclosures provided to plan participants—especially retirees. In addition, there is ongoing controversy over whether required notices and disclosures can be sent to plan participants electronically, whether they can be accessed via a website, whether they must be sent on paper, or some combination of all these delivery methods. The RFI is aimed at collecting input to help the agencies balance these controversies.

 NAIFA Staff Contact: Jayne Fitzgerald – Director – Government Relations, at jfitzgerald@naifa.org.