Alternative Reporting Methods for Apprenticeship and Training Plans and Top Hat Plans

ICR 201902-1210-001

OMB: 1210-0153

Federal Form Document

Forms and Documents
Document
Name
Status
Supporting Statement A
2019-02-07
IC Document Collections
IC ID
Document
Title
Status
212300 Modified
ICR Details
1210-0153 201902-1210-001
Active 201711-1210-002
DOL/EBSA
Alternative Reporting Methods for Apprenticeship and Training Plans and Top Hat Plans
Revision of a currently approved collection   No
Regular
Approved without change 08/16/2019
Retrieve Notice of Action (NOA) 06/18/2019
  Inventory as of this Action Requested Previously Approved
08/31/2022 36 Months From Approved 02/28/2021
1,872 0 1,872
312 0 562
0 0 4,659

Section 2520.104-22 provides an exemption to the reporting and provision of Part 1 of Title I of ERISA for employee welfare benefit plans that provide exclusively apprenticeship and training benefits if the plan administrator meets the following requirements: (1) files a notice with the Secretary that provides the name of the plan, the plan sponsor's Employer Identification Number, the plan administrator's name, and the name and location of an office or person from whom interested individuals can obtain certain info about courses offered by the plan; and (2) take steps reasonably designed to ensure that the information required to be contained in the notice is disclosed to employees of employers contribution to the plan who may be eligible to enroll in any course of study sponsored or establish by the plan; (3) and make the notice available to employees upon request. Under 2520.104-23, the Department provides an alternative method of compliance with the reporting and disclosure of Title I of ERISA for unfunded or insured plan established for a select group of management of highly compensated employees (i.e., top hat plans). In order to satisfy the alternative method of compliance, the plan administrator must file a statement with the Secretary of Labor that includes the name and address of the employer, the employer EIN, a declaration that the employer maintains a plan or plans primarily for the purpose of providing deferred compensation for a select group of management or highly compensated employees, and a statement of the number of such plans and the employees covered by each. Plan documents must be made available to the Secretary upon request, and only one statement needs to be filed for each employer maintaining one or more of the plans. The final rule revises the current procedures for filing apprenticeship and training plan notices and "top hat" plan statements with the Secretary of Labor to require electronic submission of these notices and statements. The final rule is not intended to express any view on, and does not change, the current content requirements in the exemption under § 2520.104-22 for apprenticeship and training plans or the alternative method of compliance under § 2520.104-23 for top hat plans. The final rule revises § 2520.104-22(c) and § 2520.104-23(c) to require Internet-based electronic filing of apprenticeship and training plan notices and top hat plan statements with the Secretary through EBSA's Web site. Once they are filed, these notices and statements would be posted on the Department's Web site at http://www.dol.gov/ebsa and be available to the public.

US Code: 29 USC 1023 Name of Law: Employee Retirement Income Security Act of 1974
  
None

1210-AB62 Final or interim final rulemaking 84 FR 27952 06/17/2019

  79 FR 58720 09/30/2014
79 FR 58720 09/30/2014
Yes

1
IC Title Form No. Form Name
Alternative Reporting Method Alternative to Form 5500, Alternative to Form 5500 Apprenticeship and Training Plan Registration Form ,   Top Hat Plan Registration Form

  Total Approved Previously Approved Change Due to New Statute Change Due to Agency Discretion Change Due to Adjustment in Estimate Change Due to Potential Violation of the PRA
Annual Number of Responses 1,872 1,872 0 0 0 0
Annual Time Burden (Hours) 312 562 0 -250 0 0
Annual Cost Burden (Dollars) 0 4,659 0 -4,659 0 0
No
Yes
Using Information Technology
These updated burden estimates reflect the most current data available on the number of filings and a decrease in the number of hours needed for a benefits administrator to complete the electronic filing. Additionally, with the transition to electronic filing, the Department is no longer assessing any time burden for clerical workers, nor any cost burden for materials or postage. As a result of these changes, the hour burden decreased from 562 to 321 and the cost burden decreased from $4,659 to $0.

$13,860
No
    Yes
    Yes
No
No
No
Uncollected
Allan Beckmann 202 693-8429 beckmann.allan@dol.gov

  No

On behalf of this Federal agency, I certify that the collection of information encompassed by this request complies with 5 CFR 1320.9 and the related provisions of 5 CFR 1320.8(b)(3).
The following is a summary of the topics, regarding the proposed collection of information, that the certification covers:
 
 
 
 
 
 
 
    (i) Why the information is being collected;
    (ii) Use of information;
    (iii) Burden estimate;
    (iv) Nature of response (voluntary, required for a benefit, or mandatory);
    (v) Nature and extent of confidentiality; and
    (vi) Need to display currently valid OMB control number;
 
 
 
If you are unable to certify compliance with any of these provisions, identify the item by leaving the box unchecked and explain the reason in the Supporting Statement.
06/18/2019


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