Jenner & Block

Client Advisory: DOL Finalizes New Regulations Defining when Plan Contributions Become Plan Assets: Adopts Small Plan Contribution Safe Harbor

In this client advisory, Partner Matthew J. Renaud and Associate Galen R. Mason discuss the U.S. Department of Labor Employee Benefits Security Administration’s January 13, 2010 release of final regulations modifying the existing rules governing when contributions to ERISA-covered plans constitute “plan assets.” Among other things, the authors explain the importance of timing when participant contributions become plan assets and a new 7-day safe harbor rule for small plans created by the revised regulations.