“No Duh!”was my favorite response by a colleague to the DOL’s alt asset proposed regulation, which is replete with references to the need of the fiduciary adviser to “read and critically review” the core documents of any of a plan’s investments. That proposed reg does grant plan sponsors some grace, only requiring that they (who
The DOL’s most recent advisory opinion, 2025-04, helpfully affirms two separate legal principles upon which many of the defined contribution lifetime income programs being offered in the market currently rely. The AO is also very useful in the manner in which DOL describes one very specific program, the LIS program offered by Alliance Bernstein, offering
Revenue Ruling 2012-3; the preamble to the QLAC Regs; IRS Notice 2014-66; and the Oct. 23, 2014 DOL Information Letter to Treasury are just a few of the critical building blocks which have enabled an exciting new generation of lifetime income products which we are now seeing in the market. The three 2019 SECURE ACT