I used to love paper until I had a 5-foot flood in the downstairs of my home during Hurricane Sandy. When you have a file cabinet with files sitting outside your house with files that you hope dry over 6 months, you learn to hate paper.
So that’s why I love what my friends at the American Retirement Association are calling for in their new initiative.
ARA CEO Brian Graff announced plans at the latest NAPA 401(k) Summit, to push for the elimination of the expensive and outdated ERISA requirement to disclose information to 401(k) participants in paper form.
The current rule of the Department of Labor’s ERISA regulations in information delivery is providing paper disclosures — including the Summary Plan Description (SPD) and Summary of Annual Report (SAR) — to plan participants.
There is a current safe harbor permitting electronic delivery to certain types of participants with online access. To utilize the current safe harbor, plan sponsors using electronic delivery must solicit participants’ consent to e-delivery, track their responses, store their e-mail addresses and monitor delivery of the disclosures, which is why paper delivery is still king.
