The Financial Accounting Standards Board (FASB) intends to issue enhanced disclosure requirements relating to an employer's participation in a multiemployer plan. The proposed amendment (to FASB Accounting Standards Subtopic 715-80) would be effective for fiscal years ending after December 15 2010 (for public entities) and for the first annual period after December 15, 2010 (for non-public entities).

Reinhart recently reviewed the DOL regulations regarding the obligation of multiemployer plan administrators to disclose certain information upon request (see April 2010 Employee Benefits Update.) Participating employers are likely to make additional requests for documents that may be necessary to comply with this proposed FASB amendment. As we previously reported, a plan administrator must furnish the requested documents no later than 30 days after the date the written request is received and withdrawal liability estimates (for withdrawals occurring in the plan year preceding the plan year in which the written request is made) within 180 days of the written request. However, the plan administrator is not required to furnish the requestor more than one copy of the same document or more than one withdrawal liability estimate within a 12-month period.