The Department of Labor issued on April 3 a field assistance bulletin to clarify for the administrators of defined benefit pension plans how to furnish annual funding notices to participants, beneficiaries and the Pension Benefit Guaranty Corporation and remain in compliance.
The guidance, Field Assistance Bulletin 2025-02 from the Employee Benefits Security Administration, “provides instruction to EBSA’s national and regional offices of enforcement (Offices of Enforcement) on how retirement plans in this position may comply with the new law pending additional guidance or revisions to [ERISA] 29 CFR 2520.101-5.”
According to the bulletin, confusion arose from amendments to ERISA Section 101(f) made by Section 343 of the SECURE 2.0 Act of 2022. Those amendments modified annual funding notice requirements for plan years beginning after December 31, 2023.
In the bulletin, the DOL “acknowledges that this bulletin does not address all SECURE 2.0-related issues that may arise with respect to annual funding notices.” For clarity, it continues, if plan administrators file funding notices in “compliance with the guidance in this bulletin,” the DOL will treat such action “as a reasonable, good faith interpretation of the annual funding notice disclosure requirements of section 101(f) of ERISA with respect to the issues discussed in this bulletin.”
Acknowledging that some defined benefit plans may have already prepared and begun distributing funding notices to participants, the DOL wrote that it expects plan administrators “to consider the guidance in this bulletin in evaluating whether the disclosures were consistent with a reasonable, good faith interpretation of section 101(f), as amended, and to take appropriate corrective action to the extent the plan administrator concludes that the disclosures did not meet that standard.”
The bulletin is clear that administrators of single-employer plans can no longer rely on the model funding notice provided by the DOL in Appendix A of 29 CFR 2520.101-5. Instead, the DOL directs administrators of most single-employer plans to the model notice in Appendix 1 of this bulletin.
Similarly, administrators of multiemployer plans are advised that they should rely on the model notice in Appendix 2 of the current bulletin, not the model notice in Appendix B of 29 CFR 2520.101-5.
The new bulletin also provides model wording that plan administrators can use to explain that the PBGC may pay “vested benefits greater than the guaranteed level of benefits if the terminating single-employer plan has sufficient assets.”
The bulletin offers a detailed series of 12 questions and answers as detailed guidance for plan administrators. The questions cover a range of topics, including:
When plan administrators must first comply with the SECURE 2.0 modifications to annual funding notices;
That administrators of single employers of “at-risk” plans, starting with the 2024 notice year, “do not disclose ‘at-risk’ liabilities or otherwise take the ‘at-risk’ rule of section 303(i) into account in determining the plan’s year-end liabilities and the percentage of liabilities funded”;
How plan administrators may report the required demographic information for plans, referring them, respectively, to the model language in the single-employer plan and multiemployer model notices in Appendixes 1 and 2 of this bulletin;
How to determine and disclose “average return on assets” for the notice year of both single-employer and multiemployer plans, referring administrators to Method 1 and Method 2 described in the bulletin;
That an annual funding notice for a cooperative and small employer charity plan needs to include the new demographic and average return on assets disclosures; and
That the standard has not changed for disclosing known events that will take effect at some point in the current year and are expected to have a material effect on the plan funding.
WTW makes Health, Wealth & Career appointments; Allspring Global Investments to get new CEO; Oliver Nisenson to join PGIM Fixed Income as head of Asset-Based Finance; and more.
Imran Qureshi took over from Boschetti as retirement business leader on April 2. Emory Todd will succeed Qureshi as the integrated and global solutions business leader and Michelle Acciavatti will replace Todd as North America HWC leader.
Qureshi brings more than 25 years of client and leadership experience to the retirement business. With an actuarial background and extensive multinational work, he understands the environment and opportunities for organizations in the retirement space. Qureshi will continue to hold his role as WTW’s North America leader and sit on the company’s executive team.
Emory Todd
Todd, who has also been with WTW for more than 25 years, has held consultancy and leadership roles in the work and rewards business, served as the HWC growth leader for North America and led the company’s U.S. West region. He will bring his knowledge of client issues and his ability to make connections across HWC businesses to the IGS leadership position.
Michelle Acciavatti
Acciavatti, who is an actuary and has been with WTW for more than 30 years, has held client relationship manager and leadership roles, most recently as WTW’s Midwest Region reader. As North America HWC leader, Acciavatti will be responsible for driving revenue growth across the geography, bringing new solutions to market and ensuring clients benefit from the full value of HWC insights and offerings.
Rick Sherwood will succeed Acciavatti as WTW’s Midwest Region leader alongside his role as North America leader of the IGS business. Sherwood will bring his track record of growing client relationships to his dual role where he will support both market growth in the Midwest and growth of the IGS business in North America.
Qureshi, Todd and Acciavatti are based in the U.S. and will all serve on the HWC Global Leadership team, reporting to Julie Gebauer, president of health, wealth and career.
Allspring Global Investments to Get New CEO
Allspring Global Investments, announced that Kate Burke will assume the role of chief executive officer, effective July 1, 2025. She has served as president since 2023 and is a director on the company’s board. Once Burke takes the reins as CEO, current CEO Joe Sullivan will continue to serve as executive chair of the board.
Prior to joining Allspring, Burke served as the chief operating officer and chief financial officer at AllianceBernstein.
“Since joining the team in 2023, Kate has established herself as a skilled leader who combines deep experience in asset management and an understanding of the power of people to build culture and deliver results. She has a strong client orientation, a passion for operational excellence, and a focus on maintaining strong investment performance. I am proud to pass the torch to her as she leads Allspring into the future,” Sullivan said, in a statement.
Oliver Nisenson to Join PGIM Fixed Income as Head of Asset-Based Finance
Oliver Nisenson is joining PGIM Fixed Income as head of asset-based finance, effective May 15. In this newly created role, he will be responsible for oversight and leadership of the firm’s global private ABF platform within its $131 billion securitized products business.
Joining PGIM Fixed Income from Blackstone Credit and Insurance, Nisenson will report to Gabriel Rivera and Edwin Wilches, co-heads of securitized products.
“PGIM has been a leading investor in both the public and private asset-based finance markets for more than 30 years. As such, we believe we have a unique value proposition to offer clients as the divide between public and private fades and client demand for asset-based financing and tailored investment solutions accelerates,” said John Vibert, president and CEO of PGIM Fixed Income, in a statement. “We are excited to welcome Oliver to lead and expand our private ABF team. His expertise in this space will be valuable to our team and to our clients.”
Alan Synnott Joins Mercer as Global Head of Real Assets
Alan Synnott
Mercer appointed Alan Synnott as global head of real assets in its wealth practice, reporting to Hooman Kaveh, global chief investment officer. Synnott joins Mercer from BlackRock, where he served as managing director and global head of product strategy for real assets.
Synnott will be based in Dublin and will work closely with Mercer’s global investment platform, global alternatives and regional investment teams.
“It is a privilege to join Mercer and work alongside a global team of experts across infrastructure, real estate and natural real assets,” said Synnott in a statement. “These strategies are playing an increasingly central role in the portfolios of large asset owners, serving as a potential source of capital growth, income, diversification and stability. I look forward to being a partner to our clients as we tailor strategies to meet their objectives.”
PBGC Attorney Camille Castro Joins The Wagner Law Group
Camille Castro has joined The Wagner Law Group’s Washington, D.C. office as of counsel. With more than a decade of experience in pension and employee benefits law, Castro comes to the firm after working at the Pension Benefit Guaranty Corporation.She brings brining a unique understanding of federal pension insurance programs and the intricacies of government regulations that impact plan sponsors, fiduciaries, and participants, the law firm said.
In her role at the PBGC’s Office of the Advocate, Ms. Castro served as a liaison between participants, plan sponsors and the PBGC. She assisted plan sponsors in resolving disputes with the agency involving distress terminations, post-termination negotiations, PBGC premiums, standard terminations, and other issues arising under Title IV of ERISA.
She also advised participants with benefit entitlement claims, questions about PBGC’s policies and procedures, and other complex benefits administration questions. She created the PBGC Office of the Advocate’s Pension Plan Tracing Service, designed to assist participants with historical pension plan research and related benefit claims and served as technical point of contact for a study commissioned by the advocate on pension plan de-risking. Employee Fiduciary Names Cindy Dash President
Cindy Dash
Cindy Dash has been appointing president of retirement plan provider Employee Fiduciary. Dash comes joined to the company after a long tenure at Broadridge.
“Cindy’s extensive leadership experience in scaling operations and technology platforms makes her the ideal person to lead Employee Fiduciary into its next phase of growth,” saidEric Droblyen, CEO of Employee Fiduciary, in a statement..“Her expertise aligns perfectly with our mission to provide high-quality, transparent, and low-cost 401(k) plans and our future growth plans into new markets. We’re continuously investing in improvements—like ourrecent website redesign—to better serve businesses and adviseors. I am excited to welcome Cindy to the team and look forward to the impact she will have on our clients and company.”
Principal Asset ManagementAppoints Matthew Peron as Deputy CIO of Equities
Matthew Peron
Principal Asset Management appointed has namedMatthew Peron as deputy CIO of equities and portfolio manager, a newly established leadership role.
Peron will serve as a strategic partner to George Maris, chief investment officer and global head of equities, and other senior leaders across global equity strategies to provide investment leadership, drive innovation, and advance portfolio outcomes to elevate overall client outcomes, the company said. Peron will also be co-portfolio manager for the firm’s international equity strategies, including the international equity, diversified international, and European portfolios, comprising $26 billion in assets under management.
“We are excited to welcome Matthew Peron to our team. His deep expertise across equities and investment leadership will advance our high-performance culture and strengthen our ability to deliver exceptional investment outcomes for clients across our global portfolios,” said Maris, in a statement.
Wellington Management Names Head of US Wealth
Wellington Management named Christina Kopec Rooney as the head of U.S. Wealth, based in New York. She will lead Wellington’s efforts to enhance its offerings for the wealth channel and drive growth in the U.S. market.
Rooney joins Wellington from Goldman Sachs Asset Management (GSAM), where she served as managing director and head of commercial and digital strategy for global third-party wealth.
“We are thrilled to welcome Christina to Wellington,” said Scott Geary, vice chair and head of global wealth at Wellington Management, in a statement. “Her extensive experience and proven track record in the asset management industry make her well-suited to drive our U.S. wealth strategy forward. We are confident that Christina’s leadership will help us deliver value to our clients and further grow our presence in the US wealth market.”
Penelope Adds Wagner, Crain and Kottler to Advisory Team
Retirement services platform Penelope added three senior advisors to its team: Marcia Wagner, founder of The Wagner Law Group; Kevin Crain, executive director of the Institutional Retirement Income Council; and Lisa Kottler, partner in strategic growth and innovation at KWP
“There are 34 million businesses in the U.S., yet only around 700,000 offer a 401(k)—leaving the vast majority of employees underserved,” said Jean Smart, CEO and founder of Penelope. “As states roll out new retirement mandates, [small and medium businesses] are looking for trusted partners to navigate the changes. The addition of Marcia, Kevin and Lisa to our team could not come at a better time. Their deep expertise will help us continue to expand our retirement platform, powered by a modern tech stack that takes advantage of AI. Together, we’re delivering innovative, compliant, and easy-to-use solutions that empower businesses and their employees to build a better financial future.”
