DOL releases marketplace guidance and model notices – October 1 deadline *

USA - May 15 2013
On May 8, 2013, the Department of Labor ("DOL") issued Technical Release 2013-02 ("Technical Release"), which provides temporary guidance and model…

Co-authors: Lisa Rhein Carrasco, Brandon E. Sherlinski, Andrew J. Fawbush, Kathryn K. Bongiovanni.

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DOL issues advance notice of proposed rulemaking on lifetime income illustrations *

USA - May 10 2013
On May 7, 2013, the Department of Labor ("DOL") issued an advance notice of proposed rulemaking ("ANPRM") that would require that periodic pension…

Co-authors: Lisa Rhein Carrasco, Brandon E. Sherlinski, Andrew J. Fawbush, Kathryn K. Bongiovanni.

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Agencies issue new summary of benefits and coverage requirements and templates *

USA - May 3 2013
On April 23, 2013, the Departments of Labor, Treasury, and Health and Human Services (the "Agencies") released additional FAQs addressing the…

Co-authors: Lisa Rhein Carrasco, Brandon E. Sherlinski, Andrew J. Fawbush, Kathryn K. Bongiovanni.

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Court of Federal Claims upholds application of Code section 409A to discounted stock options *

USA - March 20 2013
Section 409A of the Internal Revenue Code of 1986, as amended ("409A"), contains strict rules applicable to most forms of deferred compensation…

Co-authors: Lisa Rhein Carrasco, Brandon E. Sherlinski, Andrew J. Fawbush, Kathryn K. Bongiovanni.

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New reporting and disclosure obligations imposed by "Sunshine Act" *

USA - March 5 2013
One important provision of the Patient Protection and Affordable Care Act ("PPACA") requires certain manufacturers of drug and medical devices to…

Co-authors: Kathryn K. Bongiovanni.

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