May 22, 1997
TO: PENSION COMMITTEE No. 13-97
RE: COMMENT LETTER TO DOL ON ELECTRONIC COMMUNICATION OF SPDS
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The Institute has submitted a comment letter to the Department of Labor supporting the
electronic transfer of summary plan descriptions (SPDs) for pension plans. On April 18, 1997,
the Department published an interim rule permitting SPDs for group health plans, as well as
other health care related disclosures, to be furnished through "electronic media." The
Department also requested comments regarding the extent to which the rule should be
extended to other plans and other plan disclosures, and whether there is a need for additional
criteria to ensure private, confidential communication.
The Institute submission urged the Department to consider extending the rule for
electronic communication of group health plan SPDs to pension plan SPDs, as well as
expanding the scope of the rule to other pension plan documents and disclosures, including
participant benefit statements and summary annual reports. The Institute suggested requiring
additional passwords or security policies to ensure the confidential delivery via electronic
media of individual account or benefit-related information.
We will keep you apprised of developments regarding this issue.
Kathryn A. Ricard
Assistant Counsel - Pension
Attachment