DOL Releases Q&As on ERISA’s Annual Funding Notice Requirements Following SECURE 2.0

The Department of Labor (DOL) has released 12 Q&As and two model notices in Field Assistance Bulletin (FAB) 2025-02 regarding changes made to the annual funding notice requirements in section 101(f) of the Employee Retirement Income Security Act (ERISA) by the SECURE 2.0 Act of 2022.

Section 101(f) of ERISA generally requires the administrators of defined benefit plans (both single-employer and multiemployer) to furnish an annual funding notice to participants, beneficiaries, the Pension Benefit Guaranty Corporation, and certain other persons. Section 101(f) enhances retirement security and increases pension plan transparency by ensuring that workers receive timely and accurate notification annually of the funded status of their defined benefit pension plans. The Department last updated implementing regulations under section 101(f) in 2015.

In 2022, SECURE 2.0 section 343 amended ERISA section 101(f), modifying the annual funding notice requirements effective for plan years beginning after December 31, 2023. The major changes relate to the methodology for measuring the value of assets, value of liabilities, and funding level, and predominantly affect single-employer defined benefit pension plans.

This bulletin provides instruction to Employee Benefits Security Administration (EBSA) offices of enforcement on how retirement plans may comply with the new law pending additional guidance.

The appendices contain models that retirement plan administrators may use to facilitate legal compliance. 

Appendix 1: Single-employer pension plan model annual funding notice 

Appendix 2: Multiemployer pension plan model annual funding notice