Funding Notice Guidance for Certain Multiemployer Pension Plans

The Department of Labor (DOL) has issued Field Assistance Bulletin 2023-01 to provide annual funding notice requirements for multiemployer pension plans that received special financial assistance from the Pension Benefit Guarantee Corporation under the American Rescue Plan Act. The memorandum — in question-and-answer format — also includes model language that plan administrators may use in the annual funding notice. Pending further guidance, the DOL will treat compliance with the guidance in this Field Assistance Bulletin as constituting a reasonable, good faith interpretation of the annual funding notice disclosure requirements under ERISA Section 101(f) and applicable regulations.