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.

2019
Date Recipient Description of Request
Information Letter
2019-02-27

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.

2018
Date Recipient Description of Request
Information Letter
2018-12-04

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.

2016
Date Recipient Description of Request
Information Letter
2016-12-22

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.

2014
Date Recipient Description of Request
Information Letter
2014-12-15

J. Mark Iwry
Senior Advisor to the Secretary and Deputy Assistant Secretary
for Retirement and Health Policy
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, DC 20220

Guidance on whether retirement savings accounts established under the U.S. Department of the Treasury's retirement security program (also known as myRA) would be covered under Title I of ERISA.

Information Letter
2014-10-23

J. Mark Iwry
Senior Advisor to the Secretary and Deputy Assistant Secretary
for Retirement and Health Policy
Department of the Treasury
500 Pennsylvania Avenue, NW, Room 3044
Washington, DC 20220

Guidance under 29 CFR 2550.404c-5 and 2550.404a-4 with respect to a series of target date funds that seek to provide lifetime income through the use of unallocated deferred annuity contracts.