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Article

Loeb & Loeb LLP | USA | 29 Jan 2010

Seven-business-day safe harbor for deposits of employee contributionswage withholdings to employee benefit plans with fewer than 100 participants

Since 1988, the U.S. Department of Labor has imposed requirements as to the timing of the deposit of benefit plan employee contributionswage withholdings to the account of the applicable employee benefit plan.

Article

Drinker Biddle & Reath LLP | USA | 22 Jan 2010

Small plan seven-day safe harbor for remitting participant contributions

On January 14, 2010, the U.S. Department of Labor (DOL) issued final regulations establishing a seven-day optional “safe harbor” period in which employers may remit participant contributions to certain ERISA-covered plans with fewer than 100 participants (small plans).

Article

Jenner & Block LLP | USA | 21 Jan 2010

DOL finalizes new regulations defining when plan contributions become plan assets: adopts small plan contribution safe harbor

The timing of when participant contributions become plan assets poses important liability issues for plan sponsors.

Article

Morgan Lewis | USA | 14 Jan 2010

DOL publishes final participant contributions regulation

On January 14, the U.S. Department of Labor (DOL) published a final regulation on when participant contributions - amounts an employer has received from its employees or withheld from wages for contribution to an employee benefit plan - become “plan assets” subject to ERISA.

Article

Masuda Funai Eifert & Mitchell Ltd | USA | 31 Mar 2008

DOL announces proposed rule amending plan contribution

Under current plan contribution rules, all employers (regardless of size) must transmit participant contributions to a pension plan as soon as the participant contributions can reasonably be segregated from the general assets of the employer, but in no event later than the fifteenth (15th) business day of the month following the month in which contributions are received or withheld from the participant.

Article

Drinker Biddle & Reath LLP | USA | 5 Mar 2008

Are participant contributions remitted quickly enough?

Participant contributions to certain ERISA plans must be deposited with the plan on the earliest date on which they can reasonably be segregated from the employer’s general assets.

Article

Eversheds Sutherland (US) LLP | USA | 3 Mar 2008

DOL proposes small plan safe harbor for remitting participant contributions to plan

On February 29, 2008, the U.S. Department of Labor (“DOL”) proposed a new safe harbor, limited to small plans, under its regulation governing when participant contributions become “plan assets” for ERISA purposes.

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