- 1 -
February 13, 1991
TO: PENSION COMMITTEE NO. 3-91
RE: ERISA REPORTING AND DISCLOSURE REQUIREMENTS
__________________________________________________________
As we discussed at the last Pension Committee meeting, the
Department of Labor is considering revising the reporting and
disclosure requirements under ERISA. In particular, Assistant
Secretary Ball indicated that he was considering eliminating the
Summary Annual Report requirement for pension plans and replacing
it with a requirement that each participant receive an annual
benefit statement.
Attached is a draft letter to Mr. Ball which discusses the
need for improved disclosure under ERISA with regard to defined
contribution plans. The letter recommends that any revision to
ERISA should contemplate future technological change in the area
of pension administration and specifically recommends that plan
administrators provide the following information to individual
account plan participants at least annually and no later than 30
days after the latest valuation date:
(a) The total value of assets in the account;
(b) A breakdown showing the investment funds or media
in which the total is invested, either by percentage, number of
shares or dollar amounts;
(c) The amount of and date of contributions made to the
account together with a breakdown showing the investment funds or
media in which the contributions are invested; and
(d) The amount of and date of distributions from the
account together with a breakdown showing the investment funds or
media from which the distributions were made;
(e) A breakdown between employee contributions and
employer contributions, if relevant and, if invested in different
media, a breakdown of such investments.
- 2 -
(f) A detail of any fees applied directly to a
participant’s individual account.
If you have any comments or suggestions regarding the
attached letter, please call me by March 1, 1991.
W. Richard Mason
Assistant General Counsel
Attachment