Information Letters

Requests for interpretations and other rulings under Title 1 of ERISA are handled by the Office of Regulations and Interpretations under the provisions established by ERISA Procedure 76-1. The office answers inquiries from individuals and organizations in the form of information letters, which call attention to well established principles or interpretations.

Description of Request

Mr. Jonathan Sistare
Law Office of Jonathan B. Sistare, PLLC
P.O. Box 213
Dublin, NH 03444

Application of the authorized representative provisions of 29 CFR 2560.503-1, regarding the designation of an authorized representative for the initial claim for benefits, an appeal of an adverse benefit determination, or both.

Description of Request

Julie A. Spiezio
Senior Vice President & General Counsel
American Council of Life Insurers
101 Constitution Avenue, NW
Suite 700
Washington, DC 20001-2133

Guidance as to whether state civil laws which prohibit an employer’s implementation of an automatic enrollment arrangement in connection with a disability benefit plan or other welfare benefit plan covered under Title I of ERISA are preempted by section 514(a) of ERISA.

Description of Request

Mr. Christopher Spence
Senior Director, Federal Government Relations, TIAA
601 Thirteenth Street, NW
Suite 700 North
Washington, DC 20005

Application of ERISA's fiduciary provisions to default investments with lifetime income features that contain certain liquidity and transferability restrictions.