DOL Requests Comments on Alternative Reporting and Disclosure Methods for ‘Top Hat’ Plans

The Department of Labor (DOL) provides an alternative method of compliance with the rules for reporting and disclosing information under Title I of ERISA for special retirement plans set up for a select group of highly compensated employees (e.g., top hat plans). In order to satisfy the alternative method of compliance, the plan administrator must file a statement with the Secretary of Labor that includes the name and address of the employer, EIN, and certain declarations and statements concerning plan coverage. 

The DOL requests comments on several aspects of the alternative reporting and disclosure methods, including whether the collection of information is necessary and will have practical utility, the accuracy of the agency's estimates of the burden and cost of the collection of information, ways to enhance the quality of the information collection; and ways to minimize the burden of the collection of information.