The Pension Benefit Guaranty Corporation announced on October 14, 2026 that for 2027 premiums for multiemployer pension plans will be a flat $42 per participant. This represents a 5% increase from 2026 rates (a $2 increase) and a 40% increase from rate levels 10 years ago ($30 per participant). The increase continues the upward trend of premium rates to combat inflation, strengthen the PBGC’s financial condition, and continue the agency’s ability to provide a safety net for workers and retirees who rely on their pension benefits.
ML BeneBits
EXAMINING A RANGE OF EMPLOYEE BENEFITS
AND EXECUTIVE COMPENSATION ISSUES
AND EXECUTIVE COMPENSATION ISSUES
The Pension Benefit Guaranty Corporation (PBGC) issued Technical Update No. 26-1 on September 18, 2026, which waives on a prospective basis the requirement to report an attrition event under the agency’s reportable events regulation, which can be found at 29 CFR Part 4043.
The US Department of the Treasury and the Internal Revenue Service have finalized regulations under the SECURE 2.0 Act that change how certain retirement plan participants may make catch-up contributions. Beginning in 2026, participants whose income meets certain thresholds and who are eligible to make catch-up contributions may, in many cases, only be permitted to do so on a Roth (after-tax) basis.
In Announcement 2026-7, the Internal Revenue Service (IRS) further delayed the application of certain required minimum distribution (RMD) proposed regulations until January 1, 2027, at the earliest. The delayed proposed regulations addressed certain changes to the RMD rules made by the SECURE 2.0 Act of 2022 (SECURE 2.0).
Annual benefits enrollment, which for many companies will be in the coming months, typically lasts one to two weeks, but the preparation process begins several months in advance. For human resources (HR) and benefits teams, this period often involves a complex blend of strategic planning, system updates, vendor coordination, and employee communications. A well-executed enrollment period ensures that employees understand their options and are equipped to make informed decisions for themselves and their families.
The US administration recently issued an executive order to expand access to alternative investments in ERISA-governed retirement accounts. The order titled Democratizing Access to Alternative Investments for America's Workers aims to modernize retirement plan investment options by including alternative investments, such as private equity, private credit, real estate, and digital assets like cryptocurrency, as designated investment alternatives.
The US Department of Labor’s (DOL’s) position on the appropriateness of environmental, social, and governance (ESG) investing strategies in ERISA-regulated retirement plans has ping-ponged for decades (as we’ve covered previously). A recent statement from Trump administration attorneys in a lawsuit challenging a Biden-era regulation on the topic indicates that the ball is likely sailing back to the other side of the table and specifically to a posture that is largely skeptical that ESG investment factors can comply with ERISA’s fiduciary duties.
DOL Issues Temporary Enforcement Policy for Small Amount Transfers to State Unclaimed Property Funds
The US Department of Labor recently issued Field Assistance Bulletin (FAB) 2025-01, a temporary enforcement policy regarding the transfer of small retirement plan benefits to state unclaimed property funds. This development is part of the agency’s broader effort to help fiduciaries fulfill their obligations under ERISA to ensure participants and beneficiaries are located and receive their retirement benefits.
The US Department of Labor (DOL) has issued new guidance in the form of Field Assistance Bulletin No. 2025-02 (FAB 2025-02) and updated model annual funding notices (AFNs) for single-employer and multiemployer pension plans. FAB 2025-02 addresses some conflicts between Section 101(f) of ERISA (as amended by SECURE 2.0)—which requires the plan administrator of a retirement plan to disclose certain information to participants, beneficiaries, and other entities—and previous DOL regulations at 29 CFR § 2520.101-5.
In many situations, practitioners recommend establishing a fiduciary committee to oversee ERISA-covered employee benefit plans. There are several reasons for this, including providing a well-defined process for decision-making; bringing together a diverse team with a wide set of experience to address issues relevant to the benefit plan’s administration; managing the investment, legal compliance, and operational risks that can arise in a complex regulatory landscape; and establishing clear separation between plan sponsor and fiduciary roles.