Regulatory Representations
We regularly represent clients in dealing with the various federal regulatory agencies responsible for employee benefits. At times we have sought guidance or relief from those agencies; at other times we have responded to issues raised by the agency on audit or otherwise. We are well acquainted with responsible personnel at the Treasury, IRS, DOL, PBGC, SEC and EEOC, and with the formal and informal procedures for dealing with them. The significant matters we have successfully addressed with the agencies include:
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IRS rulings on a variety of matters ranging from pension plan qualification and deduction issues to executive compensation plans and security mechanisms, such as rabbi trusts and surety bonds.
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Resolution of IRS audits of both pension and welfare plan employee benefits issues, and correction of plan qualification defects through the IRS compliance programs.
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DOL advisory opinions, and exemptions from the ERISA prohibited transaction and funding rules, with respect to a variety of issues and transactions, including the standards for joint investment by a plan and a party in interest, and various issues involving insurance and investment products.
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Resolution of DOL fiduciary audits, including, for example, audits involving substantial plan investment in employer real property and multiple employer trust issues.
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DOL/DOJ criminal investigations.
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