Happy New Year! Ready or not, it is time for sponsors of employee benefit plans (including both retirement and welfare benefit plans) to begin paying close attention to the administrative practices and procedures that plan sponsors will need to implement throughout the year in order to comply with changes in reporting and notice requirements. Below is a summary of these changes, which include the following:

• COLA Increases for Dollar Limitations on Benefits and Contributions
• Second Five-Year Determination Letter Cycle
• Internal Claims and Appeals Process
• Summary of Benefits and Coverage, Effective March 23, 2012
• Fee Disclosure Requirements, Effective May 31, 2012
• Enhanced Disclosures for Target Date Funds

We recommend that plan sponsors allow ample time to both understand these requirements and facilitate their implementation. Of course, we will update you as compliance deadlines approach and will keep you informed of additional guidance as it is released.

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