Department of Labor – “Request for Information and Required Response”

URGENT COMPLIANCE BULLETIN

FOR IMMEDIATE RELEASE

Date:              May 20, 2021

From:             Benefits Compliance Consultants ([email protected])

To:                  All Employee Benefits Agents and Plan Administrators

Re:                  Department of Labor – “Request for Information and Required Response” inquiries related to Form M1 filings for MEWA’s

It has come to our attention that the US Department of Labor is actively reviewing Multiple Employer Welfare Arrangements (MEWAs) and is currently sending   “Request for Information with Written Response Required” notices to MEWA Administrators that have failed to file Form M1 report(s).

The DOL requires a 15-day written response to all notices and outlines all actions that MUST be completed within this time frame. These notices also make specific mention of the following civil action:

“If you were required to file the Form M1 and failed to do so, you may be liable to civil penalties of up to $1,644 per day pursuant to section 502(c)(5) of the Employee Income Security Act of 1974, as amended (ERISA).  The Department may take other action against you including, but not limited to, ordering you to cease and desist operations of the Plan, pursuant to ERISA section 521(a) and 29 CFR 2560.521-1.”

If you have received one of these notices and/or have not filed a Form M1 filing in a timely manner, don’t hesitate to contact us at (515)244-2424.

Your trusted resource for comprehensive ERISA compliance,

Benefits Compliance Consultants