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DOL Proposes Rule Requiring Electronic Filing of Top-Hat Plan Election, Apprenticeship and Training Fund Filings


October 2014

The DOL issued a proposed rule that would revise filing procedures for top-hat plan elections and apprenticeship and training fund notices. Such filings are currently made in paper form through regular mail or personal delivery, which the DOL then converts into electronic form and posts online. Because the DOL receives approximately 2,000 paper filings of top-hat plan elections and 120 paper filings of apprenticeship and training fund notices each year, it has determined that regular mail or personal delivery is no longer the most efficient or cost-effective filing method. This proposed rule would not change the current content requirements in the exemption under 29 C.F.R. § 2520.104-22 for apprenticeship and training funds or the alternative method of compliance with the reporting and disclosure requirements applicable to top-hat plans.

The electronic filing instructions for top-hat plans and apprenticeship and training funds are posted on the DOL’s website. Comments on the proposed rule are due by December 29, 2014.

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